In 2007, tax planning is getting more and more complex.

Why? For two main reasons:

One is the considerable shift of power from the tax payers to the tax authorities. The other is the increase of arbitrary decisions to the point of sometimes questioning some basic principles of law. Clearly the power of tax authorities seems to become too important.

Thus, the redrawing of boundaries between tax payers and tax authorities puts a developing pressure on sophisticated (or even simple) tax schemes.

How can individuals or corporations cope with that totally new situation? This is what the conference will be about.

Among the key topics that will be analyzed, let us mention:

 

 

• Tax Planning for cross-border M&A

• Conduit Entities: Indirect Tax-Efficient Financing Structures

• Tax-efficient structuring for investments in Europe

• Implementing a Treasury Center in Switzerland

• Revival of the Swiss finance branch: tax efficiency of the income allocation method

• International Funding Structures after Indofood – beneficial ownership and its consequences

• Anti-avoidance rules embedded within Swiss DTAs with France, Germany, Italy, and Belgium

• Practice of Transfer Pricing in Switzerland and Germany

• Realizing the European ideal: enabling cross-border activity

• EU CFC rules after ECJ’s landmark judgment in Cadbury Schweppes

• Fiscal competition for Multinationals

• A Multinationals perspective on European Taxation

• Hybrid Entities in Cross-Border Financing

• Interest deductibility: An International Perspective on Optimal Capital Structure

 

As usual with FEI conferences a selected group of speakers will address the delegates.

Glossary

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With the best Tax Planning experts...

 

Mr David Capocci

(Partner; Deloitte SA) Luxembourg

Mr Patrick Vanhaute

(Tax Lawyer; Patrick Vanhaute Advocaat) Belgium

Mr Giancarlo Cervino

(Director; Center for International Fiscal Studies) Switzerland

Dr Ramona Piscopo

(International Tax Lawyer; Loyens & Loeff) Switzerland

Dr Ludovic Verbist

(Managing Director; AAMIL Ltd) Switzerland

Mr Willem Kuiper

(Partner; Infintax) Netherlands

Mr Jacob Rigg MA

(Society of Trust and Estate Practitioners) United Kingdom

Mr Philippe Mihail

(Crédit Agricole Suisse Conseil SA) Switzerland

Mr Alexandre Weith

(Etude Bugnion) Switzerland

Mr Reto Heuberger

(Homburger AG) Switzerland

Mr Robert Anthony

(Founder; Anthony & Cie) France

Mr Hans-Georg Berg

(Partner; Skadden, Arps, Slate, Meagher & Flom LLP & Affiliates Tax) Germany

Mr Guillermo Canalejo Lasarte

(Tax Lawyer; Uría & Menéndez) Spain