PwC Fund  |  PwC Chair  |  ETC Alumni
Exclusively sponsered by
Conference "Recent Tax Treaty Case Law"
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
Tilburg University

Prof. Dr Luc De Broe
K.U. Leuven

Prof. Dr Peter Essers
Tilburg University

Prof. Dr Frans Vanistendael
K.U. Leuven



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





Practical Information

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).