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Events > Central IFA > IFA Madrid Congress 2016, Spain (25 - 30 September)

IFA Madrid Congress 2016, Spain (25 - 30 September)

12 april, 2016

The 70th Congress of the International Fiscal Association officially opened on September 25, 2016 and took place at the state-of-the-art IFEMA Convention and Congress Centre, at Recinto Ferial Juan Carlos I in Madrid, Spain.

For the Congress, an extensive and impressive range of sessions was put together, directly addressing international tax issues faced by the Congress participants at present and in the foreseeable future of the global economic environment.

Subject 1: Dispute resolution procedures in international tax matters
Many believe that the OECD's BEPS project could lead to a rapid increase in tax inspections and controversies, as well as an increase in tax disputes between governments. As tax authorities seek ways to test the limits of and possibly to broaden their corporate tax bases, the possibility of double taxation will put additional strain on the mutual agreement procedures, which may already be struggling even before BEPS to cope with demands associated with the greater internationalization of income earning activities. This panel discussed concrete proposals for addressing this global development, focusing on the root causes of increased tax controversy and challenges to typical resolution processes. The work of the FTA's MAP Forum and proposals for arbitration and other alternative dispute mechanisms were considered.

General Reporter: Carolina del Campo (Spain)
Chair: Michael Danilack (USA)

Subject 2: The notion of tax and the elimination of international double taxation or double non-taxation
The concept of 'tax' and 'tax on income and capital' is a fundamental pillar of the international tax system (tax treaties and domestic provisions on the elimination of double taxation). However, the contours of the concepts of tax and tax on income or capital are not clear. This situation often causes conflicts since States' treaty obligations may be dramatically affected if certain taxes or levies are outside the scope of tax treaties or the domestic law foreign tax credit and exemption provisions. The recent BEPS initiative is also directly linked with the concept of tax on income and capital, since, in the end, whether there is double non-taxation depends on whether income and capital have been subject to tax, or at least made liable to taxation, in, at least, one State and on the relative comparability of the taxes levied in all the States affected. The problems to be studied are directly connected with real issues that affect taxpayers and States and current controversial cases were used as a examples in the session : e.g. is the diverted profits tax in the UK covered by tax treaties? are some taxes levied in some States (e.g. to prevent abuse, taxes earmarked for a specific purpose, extraordinary taxes in periods of crisis) covered by tax treaties / domestic provisions to prevent double taxation or double non-taxation even if they do not have the form of typical taxes on income and capital?

General Reporter: Marjaana Helminen (Finland)
Chair: Adolfo Martín Jiménez (Spain)

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