Tax Law Summer School 2014

12
CATÓLICA GLOBAL SCHOOL OF LAW CUTTING EDGE LEGAL EDUCATION

description

Católica Tax Summer School on VAT and Transfer Pricing. 23 to 27 June 2014 Católica Global School of Law. Lisbon, Portugal

Transcript of Tax Law Summer School 2014

Page 1: Tax Law Summer School 2014

CATÓLICA GLOBAL SCHOOL OF LAWCUTTING EDGE LEGAL EDUCATION

Page 2: Tax Law Summer School 2014

0222001411133-272233nejununn

“I had a fantastic time inLisbon. The speakers wereof great quality, both in termsof experience - which theygenerously shared throughreal life examples - andpresentation skills.

I learned a great deal fromother students, as well, asmany were specialists in theirfield. In short, signing upwas the right professionaldecision!”

Alixe LeclercqHK University – Asian Institute forInternational Financial Law | HongKong

Page 3: Tax Law Summer School 2014

par

ptner

223333

In June 2014, Católica Global School of Law will be offeringthe third edition of its Tax Summer School comprising twoprogrammes, on Value-Added Tax and Transfer Pricing.Católica’s Tax Summer School programmes are fully lecturedin English by leading international academics andprofessionals and are aimed at students and practitionerswilling to explore two of the most fascinating and complexareas of modern taxation.

All classes are held at the Campus of the Catholic University,in Lisbon.

The VAT Programme starts with a one-day introduction tothe fundamental concepts of value-added taxation.In the following days, sessions will be held on some of themost important topics of EU VAT.

Similarly, the Transfer Pricing Programme starts with aone-day intensive introduction to the fundamentals ofTransfer Pricing, while in the following days critical topicsof transfer pricing will be covered.

Both programmes run from Monday to Friday,the Transfer Pricing sessions being held in the morning,the VAT sessions in the aernoon.

The programmes may thus be aended separatelyor simultaneously, with a special discount.

CATÓLICA GLOBAL SCHOOL OF LAWCUTTING EDGE LEGAL EDUCATION

Page 4: Tax Law Summer School 2014

TRANSFERPRICING 9:0000099

3013 333:3

TAX LAWSUMMERSCHOOLPROGRAMMES

June 23

Transfer Pricing Fundamentals 09:00-13:30H. DAVID ROSENBLOOM (New York University)

June 24

OECD Recent Developments 09:00-11:00GIANMARCO COTTANI(Italian Revenue Agency / University of Jönköping),

Recent US Case Law 11:30-12:30H. DAVID ROSENBLOOM (New York University)

Recent European Case Law 12:30-13:30GIANMARCO COTTANI(Italian Revenue Agency / University of Jönköping)

June 25

Transfer Pricing in Brazil 09:00-11:00LUÍS EDUARDO SCHOUERI (Universidade de São Paulo)

Business Transformation andPermanent Establishments 11:30-13:30JAIME ESTEVES & LEENDERT VERSCHOOR (PwC)

June 26

Intangibles and Transfer Pricing 09:00-11:00

Strategy, Management and Documentation:the view from a global company- the case of Syngenta 11:30-13:30

ISABEL VERLINDEN (PwC / Joint Transfer Pricing Forum)

June 27

Advance Pricing Agreements 09:00-10:00JOÃO GAMA (Católica Global School of Law)

Transfer Pricing Litigation 10:30-13:30C. DAVID SWENSON (PwC / Georgetown University)

“In VAT Summer School 2013I had the opportunity towitness the sharing ofinformation which is essentialto my work, transmied byexperienced professionalswho deal with this tax in adaily basis. Its scope andinternational approach werealso key factors to choose thiscourse, which has revealedto be an important tool inmonitoring the evolution ofthe themes of VAT.”

Isabel Vieira dos ReisGarrigues | Portugal

PROGRAMME DIRECTOR JOÃO GAMAWelcome DinnerJune 23, 20:00

Dinner PartyJune 27, 20:00

Page 5: Tax Law Summer School 2014

445555

VALUE ADDEDTAX 4:3301144

0019 009:0

June 23

VAT Fundamentals 14:30-19:00BEN TERRA (University of Lund / Católica Global School of Law)

June 24

VAT, Mergers & Acquisitions 14:30-16:30STEFAN MAUNZ (KMLZ)

Recent ECJ Case Law on VAT 17:00-19:00BEN TERRA (University of Lund / Católica Global School of Law)

June 25

VAT in Developing Countries 14:30-16:30SIJBREN CNOSSEN (Emm. Prof. University of Rotterdam)

Fixed Establishment 17:00-19:00HERMAN VAN KESTEREN (University of Tilburg / PwC)

June 26

Digital Transformation:VAT and Electronic Services 14:30-16:30MICHAELA MERZ (PwC)

VAT Grouping 17:00-19:00TRUDY PERIÉ (Loyens & Loeff)

June 27

Overhead Costs and VAT Deductability 14:30-16:30DENNIS JENSEN (University of Aarhus)

VAT Treatment of Public Bodies 17:00-19:00OSKAR HENKOW (University of Lund)

FEESFor each programme (separately)• Professionals: €990• Católica's LL.M. partners/ Católica alumni: €890

• Students from other schools: €700• Católica students / TLP and LawSchools Global League students:€600

• Early bird rate (30 April): €600

Fees for both programmes(simultaneously)• Professionals: €1790• Católica's LL.M. partners/ Católica alumni: €1490

• Students from other schools: €1190• Católica students / TLP and LawSchools Global League students:€990

• Early bird rate (30 April): €990

[email protected]

LOCATIOnAll classes are held at the Campus of theCatholic University, Lisbon.http://goo.gl/maps/y6AkO

PROGRAMME DIRECTOR SÉRGIO VASQUES

Page 6: Tax Law Summer School 2014

“This Tax Summer School has beenan amazing experience. I wouldrecommend all tax professionals toaend this week, not only to broadenyour knowledge but also for buildingyour network with valuable contacts.

As the lecturers are from all overthe world and from different areas,they bring a great knowledgeand value this Summer School.”

Ellen de JongW. P. Carey & Co . B.V. | The Netherlands

Ben TerraBen Terra studied international law at the University ofAmsterdam and taxation at the University of Leiden. He washead of the post-graduate training in VAT, customs andexcises at the Ministry of Finance in the Hague, professor oflaw at the University of Leiden and visiting professor at theUniversities of Florida in Gainesville, of Sydney in Australia,the Gmimo University in Moscow and the Anton the KamUniversity in Surinam. Ben was head of the global indirecttax practice of Ernst & Young until 2002 and member ofthe board of Ernst & Young tax advisors, the Netherlands.Ben has an honorary doctorate in economics from theUniversity of Lund and has published numerous articlesand books on indirect taxation. As a consultant of theOECD, the European Commission and IMF, he has beeninvolved in re-organizing tax departments, drafting law andpolicy and training tax officials in various countries includingIndonesia, the Dutch Antilles, Aruba, the Czech Republic, theSlovak Republic, Albania, the Ukraine, the Baltic States andthe CIS, Surinam and Bangladesh. At present he teachesindirect tax and European tax law at the University ofAmsterdam and the University of Lund. Ben is also lecturingat the University of Vienna, the University of Neuchâtel andthe University of Münster.

David SwensonDavid Swenson is a principal at PricewaterhouseCoopersin the Washington National Tax Services practice, GlobalLeader of PwC’s Tax Controversy and Dispute ResolutionNetwork, and is resident in the Washington, D.C. office.David is an Adjunct Professor at Georgetown University LawCenter, where he has taught courses relating to internationalcorporate income taxation continuously for 25 years.Following a prominent legal career spanning almost threedecades, David brings to PwC a wealth of experience inadvising multinational corporations on international taxmatters and has substantial experience assisting companiesin preventing, managing, and resolving tax audits anddisputes. Over the years, David has participated in morethan 250 tax controversies involving disputes betweenMNCs and the IRS, and more than two dozen other revenueauthorities around the world. Many of these tax disputeswere docketed in a U.S. court of law, proceeded to trial,and resulted in landmark judicial decisions for MNCs, andDavid also participated in several landmark tax cases

World topFaculty Be

nTe

rra

Page 7: Tax Law Summer School 2014

667777

before the U.S. Supreme Court, including the BarclaysBank, Boeing, and Goodyear cases. David has beendescribed as “one of the top five tax controversy experts inthe United States,” and has also received recognition as:one of the Top 20 Leading Attorneys in the U.S. in the areaof National Tax Litigation by “Chambers US”; one of theWorld’s Top 25 Transfer Pricing specialists by Euromoney’s;a First Tier Leading Individual in the areas of Tax Contro-versies and Cross-Border Structuring by the “InternationalTax Review”; and one of the Leading Corporate Tax Advisorsin the World by the “Legal Experts Guide”.

In addition, David received the Meritorious Service Certificatefrom the Treasury Department and the IRS. David receivedhis ML.T., from Georgetown University Law School, wherehe was Associate Editor of “The Tax Lawyer”, and his J.D.,with honors, and B.A., with distinction, from the Universityof Mississippi. David is a member of the ABA, the D.C. Bar,and has been admitted to practice before the U.S. Tax Court,the U.S. Court of Federal Claims, as well as numerous U.S.Federal Courts of Appeal, and the U.S. Supreme Court.

Dennis JensenDennis Ramsdahl Jensen has a Ph.D. degree in EuropeanVAT Law and is full-time Professor in Indirect Tax Law atAarhus University, Denmark. His primary area of research isIndirect Tax Law with emphasis on European VAT Law.Dennis teaches VAT Law to students and professionals andis Director of study at the LL.M. in VAT and Indirect Taxesat Aarhus University. He has published extensively on IndirectTax issues and hosted several seminars and conferenceson Tax Law as well as been speaker and chairman atnumerous national and international conferences.

Gianmarco CoaniGiammarco Cottani is an International Tax Adviser to theCentral Assessment Commissioner of Italy Revenue Agency,and is a Member of the Sub-Committee Group of theUnited Nations in charge of the Draft of the PracticalManual on TP for Developing Countries.

Before joining the Agency, he worked as a Transfer PricingAdvisor in the Tax Treaty and Transfer Pricing Unit of theOECD, where he was involved in the introduction of thenew Chapter IX of the OECD Guidelines.He received his degree in Law & Economics from LUISS

Rome University in 2003, an LL.M. in European and Inter-national Taxation from the European Tax College (Tilburgand Leuven) in 2005, and a Ph.D. in Corporate Taxationfrom LUISS Rome University in 2009.

Giammarco is a member of the faculty of the InternationalTax Center of the University of Leiden for transfer pricing,the Course Coordinator of the Module “Transfer PricingRules in International Taxation” at the European Tax Collegeof the University of Tilburg and he has been recentlyappointed Adjunct Professor in Fiscal Law at the JönköpingInternational Business School.

He was the National Reporter for Italy during the 2011IFA Congress held in Paris on the topic of cross-borderrestructuring.

H. David RosenbloomH. David Rosenbloom is the Director of the InternationalTax Program at New York University School of Law and amember of Caplin & Drysdale, Chartered, a law firm herejoined in 1981 after serving as International Tax Counseland Director, Office of International Tax Affairs, in the U.S.Treasury Department from 1978 to 1981.

Born in 1941, Mr. Rosenbloom graduated from PrincetonUniversity summa cum laude in 1962 and, after a year asa Fulbright Scholar at the University of Florence in Florence,Italy, attended Harvard Law School.

He graduated magna cum laude in 1966 and wasPresident of Volume 79 of the “Harvard Law Review”. Mr.Rosenbloom served as assistant to Ambassador ArthurGoldberg at the U.S. Mission to the United Nations and thenas clerk to U.S. Supreme Court Justice Abe Fortas.

A frequent speaker and author on tax subjects, Mr. Rosen-bloom has taught international taxation and related subjectsat Stanford, Columbia, the University of Pennsylvania,Harvard, and New York University Law Schools, and ateducational institutions in Taipei, Mexico City, Milan, Bergamo,Sydney, Mainz, Heidelberg, Rio de Janeiro, Pretoria,Melbourne, Vienna, and Neuchâtel. He has also served as TaxPolicy Advisor for the U.S. Treasury, the OECD, AID, and theWorld Bank in Eastern Europe, the Former Soviet Union,Senegal, Malawi, and South Africa. In recent years he hasserved as an expert witness on international tax matters inthe United States, New Zealand, Canada, Australia, andNorway.

Dav

idSw

enso

n

Den

nis

Jens

en

Gia

nmar

coCo

an

i

H.D

avid

Rose

nblo

om

Page 8: Tax Law Summer School 2014

Herman van KesterenHerman is an Indirect Taxes Partner based in Amsterdam,the Netherlands with over 20 years experience and iscurrently responsible for knowledge management andlitigation in the field of VAT. Herman received his Law Degree(Major in tax) at Leiden University and lectured EuropeanVAT at this university before transferring to Tilburg Universityin 2000, where he was appointed professor in the field ofVAT in 2003. Since 2010 Hermanm is also guest-lecturer atLeuven University (Belgium).

He is a Judge in the ‘s-Hertogenbosch Court of Appeals andin the ‘s-Gravenhage Court of first instance. Herman hasoften been a (guest) lecturer, both in the Netherlands andabroad, for academic scholars as well as for tax practitioners.

He serves as lecturer in several international programmes.At the European Tax College (the joint LL.M. programme in“International and European Taxation” of the Universities ofTilburg and Leuven), he is responsible for the “Design andstructure of consumption taxes” course.

At the Leiden International Tax Center he is responsiblefor the course Value-Added Tax Law in the Adv. LL.M. inInternational Tax Law.

Isabel VerlindenIsabel Verlinden is PwC’s Transfer Pricing Leader for Europe,Middle-East, India & Africa, a Member of PwC’s GlobalTransfer Pricing leadership team and the Partner in chargeof PwC Belgium’s International Tax and Transfer Pricingservices.

She appears in Euromoney/International Tax Review’sGuide to the World’s Leading Transfer Pricing Advisors, theGuide to the World’s Leading Tax Advisors and the Best ofthe Best Expert Guide, which identifies the top 25 best inthe world by practice area, as elected by in-house counseland peers. In her over 20 years experience she has builtup smooth relationships with Competent Authorities acrossthe globe as crystallized in many tax effective AdvancePricing Arrangements.

She has (co-) authored over 90 articles and books to date(including “Mastering the IP Life Cycle” and “Substance:Aligning International Tax Planning with Today’s BusinessRealities”).

Isabel is one of the 16 elected Business Members at theEuropean Commission’s Joint Transfer Pricing Forum. Sheactively contributes to thought leadership initiatives in thearea of TP as invitee at Specialist Business Expert GroupMeetings at the OECD. She is regularly invited to assistcountry policy makers (e.g. China to address Intangibles &TP). She will chair this year’s IFA Conference topic on “ProfitMethods and the arm’s length principle” in Copenhagen.

Jaime EstevesJaime Esteves is Partner of PwC Portugal and leads its TaxDepartment, with responsibility also for Angola and CapeVerde. He’s a specialist in Corporate Restructuring,International Tax Planning, Transfer Pricing and WealthyIndividuals. He is also a Tax Arbitror at CAAD and was thelawyer responsible for the EPSON tax case (ECJ).

He is responsible for several tax courses and lectures at anumber of Universities.

He published several studies on taxation and collaboratesregularly with leading media in tax matters.

João GamaJoão Gama teaches Tax Law at the Catholic Universityof Portugal, where he is the coordinator of Católica’sPost-Graduate Tax programme. He is the executive editorof the tax law review “Fiscalidade”.

João Gama has published on a variety of tax law topics inPortugal and abroad Belgium, The Netherlands and Brazil).After graduating from law school (2000) and obtaining hismasters degree (2004) at the University of Lisbon, he wasa visiting researcher at NYU’s International Tax Programmein 2010 and in Georgetown University in 2013, and servedas a political advisor to the President of the PortugueseRepublic between 2011 and 2013.

His Ph.D. dissertation, “The Global Word of The Taxman:Binding Rulings and APA’s” is expected in 2015. João livesin Lisbon with his wife and their five kids.

Her

man

van

Kest

eren

Isab

elVe

rlind

en

Jaim

eEs

teve

s

João

Gam

a

Page 9: Tax Law Summer School 2014

889999

Leendert VerschoorLeendert Verschoor leads the PwC Transfer Pricing ServicesGroup in Portugal and is representing Portugal within PwC’sGlobal Transfer pricing Network. He started his professionalactivity in the area of taxation in the Netherlands. In 1999 hejoined PwC in Portugal and became Partner in 2008.

He specializes in areas related to international taxation ofmultinational companies, with 19 years of experience in thesematters. Since 2002, devotes much of his time advisingPortuguese subsidiaries of multinational groups and nationalgroups with international presence in various sectors ofactivity with transfer pricing planning and transfer pricingdocumentation obligations. Leendert has a Degree inBusiness Economics from Erasmus University Rotterdamand a Degree in Tax Law from the University of Leiden, bothin The Netherlands

He is the author of the country section on Portuguesetransfer pricing rules in the book “International Transferpricing”, of the Portuguese section in the book “Masteringthe IP Life Cycle and the book “Substance, Aligning inter-national tax planning with today’s business realities” andwrote various articles about transfer pricing in economicnewspapers and the International Transfer Pricing Journal.

Luís Eduardo SchoueriLuís Eduardo Schoueri holds the chair of Tax Law at theLaw School of the University of São Paulo.

He is partner of the law firm Lacaz Martins, Pereira Neto,Gurevich & Schoueri Advogados, Vice President of theBrazilian Tax Law Institute (Instituto Brasileiro de DireitoTributário - IBDT), member of the Law Academy of SãoPaulo (Academia Paulista de Direito), and a Vice Presidentof the São Paulo’s Commercial Association (AssociaçãoComercial de São Paulo – ACSP).

He obtained his master’s degree (1992) in law at theUniversity of Munich under the guidance of Professor KlausVogel and achieved the Doctor’s and Free Professor’sdegrees at the Law School of the University of São Paulo.

Luís Eduardo is the author of several books and articlesand studies published in Brazil and abroad, and hasalready lectured as Visiting Professor at the University ofFlorida, at the University Paris I Pantheon-Sorbonne and atthe Vienna University of Economics and Business.

Michael TumpelMichael Tumpel is a full-time Professor of Tax Managementof the University of Linz, Austria and Director of a LL.M. inEuropean Tax Law and of a MBA programme.

He chairs the Indirect Tax Committee of the AustrianChamber of Tax Advisers and is a Member of the IndirectTax Committee of CFE. He is the author of many books andarticles on VAT Law, European Tax Law and InternationalTax Law.

Michaela MerzMichaela is Indirect Taxes Partner at PwC and ITX CentralCluster Leader.

Her expertise includes advising domestic and multinationalcompanies in national and international VAT issues, advisingon their worldwide VAT positions and leading worldwideproject teams, structuring and implementation of principaland supply chain structures and an in-depth experiencewith global business structures, cross border transactions,outsourcing (Shared Service Centre) and restructuring.

She is a specialist in e-biz and e-commerce.

Leen

dert

Vers

choo

r

Luis

Edua

rdo

Scho

ueri

Mic

hael

Tum

pel

Mic

hael

aM

erz

Page 10: Tax Law Summer School 2014

Oskar HenkowAssociate Professor (L.L.D.) Oskar Henkow is a teacherand researcher at Lund University, Sweden, exclusivelyfocused on indirect taxes and the Value Added Tax (VAT) inparticular. His thesis, published by Kluwer Law Internationalin 2008, dealt with the VAT treatment of financial activities.In January 2013 he published a study on the VAT/GSTtreatment of public bodies, which is a legal comparativeresearch of the EU system, the municipality VAT compen-sation funds and the GST treatment of public bodies onNew Zealand. He is Programme Director of the Master’sProgramme in European and International Tax Law, at LundUniversity, the Editor in Charge of the Case law and Leg-islative Development Sections of the World Journal ofVAT/GST Law and an alternate member of the EuropeanCommission’s VAT Expert Group.

He has published numerous articles dealing with VAT andis a regular teacher and presenter both in the private andpublic sectors. He also has an extensive experience as atax consultant and advisor contracted by the IFC of theWorld Bank to provide advice on VAT legislation.

Sérgio VasquesSérgio Vasques is a Tax Law Professor at the CatholicUniversity of Portugal and Católica Global School ofLaw. He holds a Masters Degree and a Ph.D. in Tax Lawand his main field of work is that of indirect taxation andenvironmental taxes.He has taken part in the drafting of the PortugueseExcise Duties Code, the reform of vehicle taxation andthe introduction in Portugal of environmental charges onwater and waste, among other projects.In recent years he has done extensive work in Africa,where he’s worked on the reform of VAT, exciseduties and other indirect taxes. Sérgio held the post ofSecretary of State for Tax Affairs of Portugal in the years2009-2011.

Sijbren CnossenSijbren Cnossen is the Academic Partner of CPBNetherlands Bureau for Economic Policy Analysis, andProfessor of Economics at the University of Pretoria.

He is Emeritus Professor of Tax Law of Erasmus UniversityRotterdam and Emeritus Professor of Economics of theUniversity of Maastricht. He has also held appointments atthe Law Schools of the Universities of Harvard, New Yorkand Florida, the College of Europe, and the NetherlandsInstitute for Advanced Studies. Professor Cnossen hasbeen an advisor to the IMF, the World Bank, the OECD, theEuropean Commission, and USAID.

He has published widely on the economics of taxation,including the VAT, excise duties, personal and corporateincome taxes, and the coordination of tax systems incommon markets.

Stefan MaunzDr. Stefan Maunz is a lawyer and certified tax consultant.With many years of experience in VAT and customs law,Stefan is a partner at KMLZ, a German law firm currentlyspecializing in these areas. In addition, he has extensiveexperienceworking for international law firms in both Germanyand the USA. He is a visiting lecturer at the University ofMunich as well as a VAT Forum partner and Member of theVAT Expert Group initiated by the EU Commission.

Trudy PeriéTrudy Perié (1962), tax lawyer, is a member of the VAT,customs and international trade practice group. She isheading the Amsterdam part of this practice group.

She specialises in VAT, customs and excise duties, and is– inter alia – involved in real estate transactions, interna-tional trade, the finance sector (securitisations, holdings,investment funds), as well as the energy sector.

She started her career as a VAT inspector with the TaxAuthorities. During her employment at the Amsterdam officeof one of the Big Four firms she also worked in New York.

Trudy has written many articles on indirect taxation and isan editor of a biweekly legal magazine. She lectures on VAT,for example for the Dutch Association of Tax Advisers andis a guest lecturer at the University of Maastricht. She is anactive member of the International Bar Association.

Osk

arH

enko

w

Sérg

ioVa

sque

s

Sijb

ren

Cnos

sen

Trud

yPe

rié

Stef

anM

aunz

Page 11: Tax Law Summer School 2014

10111111111

“The Tax Law Summer Schoolon VAT and Transfer Pricing in Lisbonare exceptional. The programmesare very well structured and taughtby the best tax academics andprofessionals in these areas.The five day courses give you all thetheoretical and practical backgroundyou need to work on these areas.”

Miguel nicolasPh.D. student in International and

European Tax Law | University of

Cergy-Pontoise | France

LISBOnLisbon provides the historicalbenefits of being in the placewhere the first step towardsglobalization was takencenturies ago.Lisbon has a vibrant modernambiance, affordable livingcosts, and sits poised as thegeographical and strategicbridge between Europe andthe United States.

USEFUL SITESwww.visitlisboa.comwww.lisbonwalker.comwww.agendalx.ptwww.cm-lisboa.ptwww.visitportugal.comwww.ipmuseus.pt

Page 12: Tax Law Summer School 2014

0001422220000bonLLLiisbossbbo

OTHERPROGRAMMESROLLINGAPPLICATIONS2014-2015

Advanced LL.M. in International Business Law

LL.M. Law in a European and Global Context

Global Ph.D. Programme

Master in Tax Law(taught in Portuguese and in English)

Graduate Programme in Taxation(taught in Portuguese)

INFORMATION:[email protected]