| 09.00 |
Anti-avoidance Provisions in Tax Treaties |
Mario Petriccione |
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- Can treaty benefits be denied in cases of tax avoidance?
- The beneficial ownership test
- Limitation of benefits clauses
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- Mechanical v. motive-based tests
- The US approach
- LOB clauses in Indias treaty network
- The way forward
|
|
| 09.40 |
Money Laundering and Tax Advice |
Robert Ham |
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- Understanding the offence
- Routine precautions
- "Suspicion" and its consequences
- Retaining records
|
|
10.20 |
Coffee |
|
10.50 |
Symposium: Two OECD Initiatives |
Speakers: Jeffrey Owens & Richard Hay
Moderator: Richard Pease |
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1. The HNWI Project |
|
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- Scope of the project - Improving co-operative compliance
- The consultation process - The way forward
|
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2. Transparency, Exchange of Information and the Global Economy |
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- Tax competition - The level playing field
- Exchange of information with the international financial centres
- Recent initiatives - TIEAs or DTAs
|
12.10 |
Pre-lunch drinks, followed by set lunch |
|
| 14.30 |
Discussion Session I |
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| 15.10 |
Tea |
|
| 15.35 |
Discussion Session II |
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| 16.15 |
Review of Discussion Sessions |
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| 16.45 |
Close
of Day One |
|
| 18.30 |
Reception, hosted by Barclays Wealth |