International Tax Conference 2023, September 29th, Milan

RECENT TRENDS ON PERMANENT ESTABLISHMENT, BUSINESS NEXUS AND PROFIT ALLOCATION

Agenda
After the successful completion of its first event in Belgrade, the International Tax Law Research and Policy Network (ITLRN) will host on September 29th, 2023, its second international tax event in Milan (Italy) to discuss “Recent Trends on Permanent Establishment, Business Nexus and Profit Allocation”.
With respect to the organisation of the event, ITLRN (the founding members which originate from the University of Lausanne, University of Belgrade, University Carlos 3 Madrid and members of Practise) has joined forces with two other universities, respectively the Catholic University of Piacenza (Italy) and the Vienna University of Economics and Business (WU, Austria). The event is also organized under the aegis of Assonime (Association of Italian Joint Stock Companies).
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Objectives
The event program consists of four main sessions. After selected opening / keynote addresses, the first session starts with a panel addressing the emerging policy and technical issues / trends on permanent establishment, business nexus and profit allocation. Speakers on this panel include representatives from the OECD, Academia, the Italian Revenue Agency and the business community.
The second session aims at discussing the current permanent establishment and profit allocation issues in different sectors such as banking, insurance, investments funds, energy, broadcasting/TV rights and health care sectors.
The third session of the event focusses on the tech industry and analyses such issues
in the online streaming, online intermediation, metaverse, crypto, and AI driven sectors. Additionally, the related VAT aspects shall be discussed.
The fourth session analyses the issue of nexus and profit allocation in the aftermath
of the OECD Pillar One and Two projects. Moreover, it focusses on dispute prevention
and resolution mechanisms under the current and new systems.
The conference concludes with a roundtable discussion with additional comments, inputs, suggestions from all conference participants with respect to further policy work that
can be accomplished in this area with the objective of obtaining tax certainty.
The speakers in this event include renowned experts with different backgrounds coming from academia (prominent professors representing nine different universities), private practice (international corporate tax and transfer pricing partners), tax directors from different MNEs as well as government officials and senior experts from public policy institutions, both at national and international level (including the OECD and the European Commission).
Milan – Hotel Principe di Savoia

September 29th, 2023

8:45 AM to 9:00 AM:
Opening of the Conference
Introduction by the ITLRN members
Opening Remarks
On. Maurizio Leo*, Vice Ministro, Ministero dell’Economia e delle Finanze
Prof. Dr. Marco Allena (Università Cattolica del Sacro Cuore di Piacenza)
Luca Occhetta (Pirola Pennuto Zei & Associati)
* Subject to confirmation
9:00 AM to 9:20 AM
Introductory speech on the relevance of the topic
Prof. Dr. Philip Baker (King’s Counsel, United Kingdom)
9:20 AM to 10:45 AM: SESSION 1
Emerging trends on permanent establishment, business nexus and profit allocation
Chairs: Prof. Dr. Pasquale Pistone (IBFD, University of Salerno, WU) and Dr. Mario Tenore (Pirola Pennuto Zei & Associati)

9.20 am to 9.45am – Key note address: Manal Corwin (Centre for Tax Policy and Administration, OECD)

Followed by a panel discussion by:
⟹ Alan McLean (Business at OECD, BIAC)
⟹ Anna Luigia Cazzato (Large Business Taxpayers Unit, Italian Revenue Agency)
⟹ Giacomo Soldani (EssilorLuxottica S.A.)

15 Mins:
Coffee Break
11:00 AM to 12:45 PM: SESSION 2
Current permanent establishment and profit allocation issues in selected industries
Chairs: Dr. Raffaele Petruzzi (WU Transfer Pricing Center, Institute for Austrian and International Tax Law, WU) and Prof. Dr. Svetislav Kostic (University of Belgrade)

⟹ Banking – Federica Pitrone (Intesa Sanpaolo)
⟹ Investment Funds – Paolo Ludovici (Gatti Pavesi Bianchi Ludovici)
⟹ Energy – Pietro Bracco (AndPartners)
⟹ Broadcasting/TV rights – Pamela Palazzi (Sky Italia)
⟹ Health Care Industry – Céline Martin (Riedweg)

60 Mins:
Lunch Break
1:45 PM to 3:30 PM: SESSION 3
Permanent establishments and profit allocation issues in the context of highly digitalized business models
Chairs: Prof. Dr. Andrés Báez Moreno (University Carlos III Madrid)
and Prof. Dr. Paolo Arginelli (Università Cattolica del Sacro Cuore di Piacenza)

⟹ Online Streaming – Gianmarco Cottani (Global Tax Policy, Netflix)
⟹ Metaverse / Crypto Industry and PEs – Marcel R. Jung (MME Legal Tax Compliance)
⟹ AI and PEs – Francesco Avella (Studio Avella e Associati)
⟹ VAT Perspective – Bruno Ferroni (Miccinesi Tax Legal Corporate, Assonime)

30 Mins:
Coffee Break
4:00 PM to 5:00 PM: SESSION 4
Permanent establishments in the aftermath of Pillar One and Two
(including dispute prevention and resolution mechanisms)
Chairs: Prof. Dr. Vikram Chand (Tax Policy Center, University of Lausanne)
and Prof. Dr. Tommaso Di Tanno (LUISS University, Master di Impresa)

⟹ EU Developments – Mauro Faggion (European Commission)
⟹ Pillar 2 and PEs – Giovanni Rolle (WTS R&A Studio Tributario Member of WTS Global)
⟹ Allocation of profits to PEs under Pillar II for different industries – Emmanuel Llinares (Nera Economic Consulting)
⟹ Allocation of covered taxes to PEs under Pillar II – Stefano Grilli (STS Deloitte)
⟹ Airline Industry and PEs – Lígia da Fonseca (International Air Transport Association – IATA)
⟹ US Approach – David Farhat (Skadden, Arps, Slate, Meagher & Flom LLP)

5:30 PM to 6:15 PM: Closing Roundtable
Chairs: Prof. Dr. Giuseppe Melis (LUISS University) with the organising members, Prof. Dr. Paolo Arginelli, Prof. Dr. Andrés Baéz Moreno, Prof. Vikram Chand, Prof. Dr. Svetislav Kostic, Dr. Raffaele Petruzzi, Dr. Mario Tenore
6:00 PM to 6:30 PM: Introduction to next event of the ITLRN
Presentation of the third event to be hosted by ITLRN – Dr. Marco Felder
(Felder Sprenger + Partner AG)
6:30 PM Onwards: Networking Drinks
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