20 October 2010
In today’s environment of largely globalizing national economies, individuals and companies maintain a diversified range of cross-border economic relations.
Tax treaties have traditionally dealt with issues of international double taxation that may arise within these cross-border relationships. The interpretation
and application of tax treaties is becoming an increasingly complex matter in today’s globalizing economic environment. The body of international case law in
the field of tax treaties has grown commensurately. During this conference, we want to examine and discuss recent tax treaty cases which, although decided in
one country, may also have an impact on the interpretation and application of tax treaties in other countries.
This conference highlights nine recent tax treaty cases decided by courts in various jurisdictions and focuses on four main themes in tax treaty law:
residency, classification conflicts, business profits of a permanent establishment, and beneficial ownership. Internationally renowned experts in the
field of tax treaty law have been invited and will discuss a recent case from their country. Participants are subsequently invited to briefly comment
on the impact of these cases on the interpretation and application of tax treaties of their respective home countries and to consider whether there will
be a need to adjust existing tax treaties.
The conference is organised to celebrate the inaugural address of Prof. Brian Arnold, who will be holding the rotating PricewaterhouseCoopers International
and European Tax Chair this academic year.
You are kindly invited to join the conference as a participant.
|
Prof. Dr Eric Kemmeren
|
Prof. Dr Peter Essers
|
| Programme | |
| 09:00-09:30 |
Welcome and Registration at the congress venue |
| 09:30-09:45 |
Opening by Prof. Dr Eric Kemmeren, Tilburg University |
| 09:45-11:45 | Theme 1: Residence Moderator: Prof. Dr Peter Essers, Tilburg University |
| 09:45-10:15 | UK: Laerstate BV and UK Corporate Residence (UK-NL DTT)
Malcolm Gammie QC, Institute for Fiscal Studies |
| 10:15-10:45 | NL: Dutch Tax-Exempt Association and Tax Liability (NL-USA DTT)
Prof. Dr Eric Kemmeren, Tilburg University |
| 10:45-11:15 | GER: Residence and Qualification of Florida LLC (GER-USA DTT)
Prof. Dr Jürgen Lüdicke, Hamburg University |
| 11:15-12:15 | Theme 2: Classification Conflicts
Moderator: George de Soeten LL.M, Tax Partner, PricewaterhouseCoopers |
| 11:15-11:45 | UK: Bayfine UK, Foreign Tax Credits and Hybrid Entities (UK-USA DTT)
Prof. Dr David Southern, Queen Mary and Westfield College (University of London) |
| 11:45-12:15 | BEL: ING Lease Belgium, Foreign Tax Credits and Operational versus Financial Lease (BEL-CZECH DTT)
Prof. Dr Luc De Broe, K.U. Leuven |
| 12:15-13:30 | Lunch |
| 13:30-14:30 | Theme 3: Permanent Establishment and Business Profits Moderator: Prof. Dr Luc De Broe, K.U. Leuven |
| 13:30-14:00 | FRA: Zimmer and Commissionaire Structure (FRA-UK DTT)
Prof. Dr Daniel Gutmann, University Paris-1 Panthéon-Sorbonne |
| 14:00-14:30 | GER: Transfer of Enterprise and Transfer of the Entrepreneur's Residence (GER-BEL DTT) Prof. Dr Ekkehart Reimer, Heidelberg University |
| 14:30-15:30 | Theme 4: Beneficial Ownership
Moderator: Daniël Smit LL.M, Tilburg University |
| 14:30-15:00 | IT: Transparent Entities, Investment Management, and Dividends (IT-JAP DTT)
Prof. Dr Pasquale Pistone, University of Salerno, WU Vienna University of Economics and Business |
| 15:00-15:30 | SPA: Aromatics Holding Limited, Conduit Company and EU Directive and Treaty Shopping (SPA-NL DTT)
Prof. Dr Adolfo Martín Jiménez, University of Cádiz |
| 15:30-15:45 | Closing by Prof. Dr Eric Kemmeren, Tilburg University |
| 15:45-16:15 | Coffee Break |
| 16:15-17:00 | Inaugural address Prof. Brian Arnold, “Taxing Income from Services under Tax Treaties: Cleaning Up The Mess” |
| 17:00-18:00 | Reception |
Date and time
The conference takes place on Wednesday 20 October 2010, from 09:30h to 17:00h (registration as from 09:00h). There will be a reception afterwards.
Participation fee
The participation fee for the conference is EUR 500 (including lunch and drinks).
Registration
Please click here to register. As the number of places is limited,
registrations will be handled on "first come first served" basis.
Registration is possible until 12 October 2010.
Venue
The conference will be held in lecture hall TZ 4 (Tias Building) at the campus of Tilburg University. An electronic map of the campus is
available here.
Visiting address of Tilburg University:
Warandelaan 2, 5037 AB Tilburg, The Netherlands.
How to reach us
By car:
There is ample parking on the campus. By using the following address in your Sat Navigator, you will reach the parking lot closest to the Tias Building
on the Tilburg University campus:
Hogeschoollaan 100, 5037 GD Tilburg.
Tilburg University, Tias Building
By public transport:
The Tilburg University campus is within walking distance of Tilburg West railway station.
For more information, please consult the English website of the Dutch railways.
Airports:
The nearest international airports to Tilburg are:
- Eindhoven Airport (Eindhoven) (approximately 30 min by car)
- Schiphol Airport (Amsterdam) (approximately 1:30h by train)
- Rotterdam The Hague Airport (Rotterdam) (approximately 55 min by car)
- Brussels Airport (Brussel) (approximately 1:15h by car)
Accommodation
If you would like to make a hotel reservation, we suggest the following accommodations:
Ibis Hotel
Phone: +31 (0)13 463 64 65
Website: Ibis Hotel Tilburg
If you state “Tilburg University Conference” when you book a room, you will receive a discount.
Mercure Hotel
Phone: +31 (0)13 535 46 75
Website: Mercure Hotel Tilburg
If you state “Tilburg University Conference” when you book a room, you will receive a discount.
City Hotel
Phone: +31 (0)13 535 13 55
Website: City Hotel Tilburg
Bastion Hotel
Phone: +31 (0)13 544 19 99
Website: Bastion Hotel Tilburg
Further information
If you need further information, please contact Yvonne van Hapert or Eva Schupp (e-mail: ETC@uvt.nl).

