Same same but different

The clash of anti-avoidance rules

In past years, we have witnessed numerous anti-tax avoidance regimes put in place. We are now seeing an increase in conflicts between international anti-avoidance measures and domestic anti-avoidance rules. Has the rollout of the international regimes resulted in a situation of double, or even multiple taxation—on the basis that the various laws target similar situations but are different? For example, where CFC income is taxed under ATAD 2—is this tax then taken into account for Pillar 2? What if one of the companies involved is also a subject to the upcoming ATAD 3? How do national anti-avoidance rules influence this determination?

This conference will explore these grey areas as we look to see whether there is a pathway to clarity!

A detailed program will follow. 

In the meantime, you can get an impression of the last Global Tax Conference in 2023 by watching this video (link). 

We hope you will join us - you can confirm your attendance already now by sending an email to taxconference@dentons.com.