すべてアプリで閲覧するようになっていて、スマホ上で完結する感じだが、バックアップのために２つのMain Subjectsについてこのサイトからコピペしておこう。なお、Cahiersについてはここを参照。
Main subjects
Sharing and shifting of corporate losses – The new profit shifting?
General reporters
René Matteotti (Switzerland)
Chair: Sam Kaywood (USA)
The panel will review arrangements to shift of losses among entities in a multinational group to optimize tax planning as well as tools deployed by tax authorities to combat them. In particular, the panel will cover the migration of assets or companies with built-in losses to other jurisdictions, the duplication of losses in different countries, the use of transfer pricing arrangements to transport profits or losses (through the migration of intangibles or otherwise), techniques to refresh expiring tax attributes and the use of financial arrangements to base erode a high-tax jurisdiction while creating stateless income. The panel will explore specific tools to implement these arrangements, including the use of dual resident companies, cross-border reorganizations, hybrid instruments and hybrid entities. The panel will also consider the use of “soft doctrines” to attack these arrangements as well as the impact of Pillar 2.
Panel Members:
Sylvia Dikmans (Netherlands)
Yushi Hegawa (Japan)
Don Maher (USA)
Carlos Orsolon (Brazil)
Juan Carlos Perez-Peña (OECD)
José Carlos Silva (Mexico)
Jason Yen (USA)
Secretary:
Ximena García Torres (Mexico)
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Good faith in domestic and international tax law
General reporters
Craig Elliffe (New Zealand) and Sjoerd Douma (Netherlands)
Chair: Hon. Marshall Rothstein, CC, KC (Canada)
Good faith is a fundamental legal principle in international law and most domestic legal systems worldwide, both civil and common law. The meaning of good faith varies across different contexts and jurisdictions, which can be a challenge in the international context where consistency is desirable. In the domestic tax context, good faith can be relevant to the relationship between taxpayers and tax authorities. In the international tax context, the good faith principle applies to dealings between contracting States, in particular to tax treaties and their interpretation. It is similarly relevant to dealings between taxpayers and the tax authority of a contracting State. This panel will explore various issues, focusing on the history and foundation of the principle of good faith in the international context; the application of this principle in the tax treaty context, including potential remedies for breaches; and the application of this principle against the background of selected current issues in international tax practice and illustrated by specific case studies.
Panel Members:
Vanessa Arruda Ferreira (IBFD Brazil)
Céline Braumann (Canada)
Luzius Cavelti (Switzerland)
Daniel Gutmann (France)
Sachit Jolly (India)
Secretary:
Ilana Ludwin (Canada)
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