International Conference update

Gabelle partners Kevin Offer, Paul Bramall and Caroline Fleet recently presented and took part in the Annual International conference of ITSG (International Tax Specialist Group) in Munich.

The conference covered a number of international hot tax topics varying from the implications of Brexit, the overall BEPS programme and the Common Reporting Standard to the ECJ’s Apple decision and State Aid. Kevin led the session, looking at international athletes and entertainers and the various specialist tax systems in place around the world designed to attract such individuals.

Caroline presented the Transfer Pricing session, looking at how the UK tax authorities are taking forward a number of the BEPS proposals and introducing legislation that arguably allows them to tax profits that have remained out of reach as a result of straightforward transfer pricing adjustments. In particular, she addressed the Diverted Profit tax and Property Development tax.

One of the liveliest lectures of the conference was led by Paul, exploring whether it was possible for an individual to be tax resident nowhere. Although in theory it was possible for an individual to organise their lives such that they were not tax resident in any country, this kind of arrangement requires very careful consideration of a number of factors including where they physically spend their time and where they have assets and other socio-economic ties. In addition, it was noted that being tax resident nowhere can have some practical difficulties particularly from a banking perspective.

On the final day of the conference there was a quick fire round of updates from around the world outlining the key tax changes affecting each jurisdiction. With the forthcoming non-dom changes just around the corner in the UK, it was quite clear that a number of other countries, notably Portugal and Cyprus, have looked to make themselves more attractive to globally mobile taxpayers and to encourage these individuals to their countries. For those advisers with clients who are contemplating leaving the UK as result of the forthcoming changes, the tax implications of where they go is a crucial part of the decision and there are a number of options available.

ITSG is a network of independent tax practices across the world and brings together a team of international tax advisers, each of whom are recognised tax specialists in their own jurisdiction. Gabelle is the representative UK firm for the international network.