For this meeting we are delighted that three of the most experienced and knowledgeable speakers in this area will be joining us to share their perspectives on what is happening in practice with the MLI:
Many of you will know Jonathan is a leading global expert on tax treaties & the MLI implementation and he will share his views on what he is seeing so far, including (i) the Principal Purpose Test and the Canadian decision in Alta Energy; (ii) dispute resolution and the arbitration provisions; and (iii) some comments on the utility and user-friendliness of the MLI.
Tom will also bring a wealth of knowledge and HMRC perspective on the topic, he will share some facts and figures on the take up of particular provisions plus an HMRC perspective on the overall merits of the MLI approach, their views on some practical issues that have arisen to date, as well as possible future uses of the MLI approach.
Peter is a leading EU expert on tax treaty matters and will bring a European perspective, in particular regarding prevention of treaty abuse, the broadening of the PE definition and the MAP for dual resident entities. In addition Peter will explore the Principle Purpose Test in relation to EU abuse of law case law / EU GAARs.
So overall this should be a really fascinating and informative session which is highly recommended!
Please register for this event by e-mailing Karen Spring at karenspring@ifa-uk.org Guests can also be registered by contacting Karen.
