IFA 2006: what to expect from this year IFA

With less than one month to the annual meeting of IFA (a congregation of international tax fanatics), which this year is in my adopted town of Amsterdam (relieving me of big trips), it is time to make an overview of the various topics that will be discussed between 17-22 September 2006.

As usual the congress evolves around two plenary sessions (tax consequences of restructuring of indebtedness and attribution of profits to permanent establishments), which are coupled with break out-sessions (related to such topics) and additional seminars on other pre-selected topics.

The first topic is tax consequences of restructuring of indebtedness. This topic, which explores several debt restructuring scenarios originating from situations of corporate distress analyses the tax treatment of different types of work-outs from a comparative perspective. The first session will focus on tax consequences to unrelated creditors and debtors of debt restructurings, while a special breakout session will analyse the situation where debtor and creditor are related parties.

The second topic addresses the already controversial topic of attribution of profits to permanent establishments (PEs) under the OECD Model Tax Convention. In the wake of delays as to the conclusion of the OECD project on attribution of profits to PE’s, the work of IFA gains more importance since from the branch reports it is already visible differences in the approaches and potential implementation issues and difficulties of the so-called authorised OECD Approach. The same topic is followed up in two breakout sessions, one dealing with specific issues concerning the financial service industry and the other focusing on EU/non-discrimination issues.

With respect to the seminars, it should be mentioned that:
- Seminar A will focus on Indirect tax aspects of cross-border services;
- Seminar B will focus on the concepts of “enterprise” and “business” which are used throughout the OECD Model Tax Convention;
- Seminar C will address international cooperation in countering tax avoidance from a policy and administration perspective;
- Seminar D will focus on the effect of regional and global trade agreements on domestic tax law and bilateral tax conventions;
- Seminar E that normally address recent developments in international tax will focus this year on Chinese incentives and the US fight against inversions;
- Seminar F will discuss the need and scope for coordination of tax policies in the EU; and
- Seminar G will address the increasingly important issue of the relationship between tax accounting and commercial accounting.

But this year the IFA is not only two plenary sessions and seminars but also about the launch of the young IFA network (YIN). Having been actively involved in the launch of this idea, I hope this year will be a YIN year for IFA!

For a more complete overview of the congress activities visit the website of the IFA congress.