invitation to international tax summer school

The 1st MediterraneanInternational

Tax Law Summer School

24-30 June , 2013

in cooperation with University of Rijeka

andCentral Asian Tax Research

Center

Combined with Celebration of Croatia’s Entry into EU on the midnight of June 30/July1st

11stst Mediterranean Mediterranean International Tax Law International Tax Law

Summer SchoolSummer School• International tax law summer school is designed to bring together

international tax specialists from Mediterranean states as well as the mid-career tax professionals seeking to advanced their international tax knowledge, get new practical ideas and expand their professional network.

• Summer school will make it also possible to incorporate the participation of young tax professionals in the Big 4, Consulting and Law Firms.

• This one week long interactive learning program, will incorporate practical aspects of international taxation both inbound and outbound as well as transaction based with focus on practical implications and relevance to Mediterranean states and practitioners.

• Working language of the summer school is English

© 2013 Central Asian Tax Research Center

Why shall you attend?Why shall you attend?

• International Summer School is a great opportunity for young and mid-career tax professionals to meet their colleagues from Mediterranean states as well as other countries and further jointly develop as well as share both experience and knowledge in international taxation.

• This program can be also considered as a good training for newly admitted employees who start working in September and want to advance their international tax knowledge.

• Are you engaged in tax advise for a client in Mediterranean region?

• Then this school is a unique opportunity to get first hand knowledge and understanding of the tax practices and underlying tax policies.


Program - Day 1Program - Day 1


TimeTime TopicTopic DescriptionDescription

09:00 Opening, Overview of the Course, Introductions

09:30-12:00 Revision of fundamental principles on the basis of

practical Cases

• Residence-based taxation• Source-based taxation• Double taxation issues• Practical cases based on domestic law

of participating countries

12:00-13:00 Tax Treaties through practical cases

• Role and importance of tax treaties• Relationship between tax treaty and

domestic tax law• Scope of tax treaties (Persons and

Taxes Covered)• Structure of tax treaty

13:00 Welcome lunch

14:00-15:45 Tax Treaty Cases continued • Comparison of OECD and UN Model Treaties

• Types of allocation rules of treaties• Double tax relief• Practical Case

15:45 Break

16:00-18:00 Tax Treaty Network and Treaty Interpretation

• Review of Tax Treaty Network of Participating Countries

• Analysis of Vienna Convention• Interpretation of tax treaties

18:00 Networking Reception



TimeTime TopicTopic DescriptionDescription

09:00-10:45 International Tax Planning Structures, Residence and Denial of Treaty Benefits

• Fundamentals of Tax Planning• General rules: which companies are

allowed to invoke the tax treaty• International assignment of executives

and technical staff: When will host states claim the assigned person is taxed as a resident; How canthis be avoided

• Treaty shopping, residence questions and anti-abuse measures: how will tax authorities deny treaty benefits

11:00-13:00 Permanent Establishment Concept

Existence of PEBusiness Models

• Introduction• Basic rules for the PE concept• Definition of PE in OECD and UN

Models (Art 5)• Auxiliary and Preparatory activities• Construction sites PE• Agency PE/Service PE• Practical cases

13:00 Lunch

14:00-15:45 Business Profits • Analysis of Article 7 of OECD Model Tax Treaty: Taxation at Source of Business Income and PEs

• Determination of business profits• Arm’s length principle• Allocation of head-office expenses• Practical Cases

16:00-18:00 Employment Income • Taxation of dependent personal services

• General rules• Directors’ fees• Artists and sportsmen

18:00 Teambuilding activity


Program - Day 3Program - Day 3TimeTime TopicTopic DescriptionDescription

09:00-10:45

Holding structures, financing, licensing intellectual property

and leasingequipment

• Choosing a suitable holding jurisdiction and shareholding structure

• Tax implications of international project finance

• Licensing patents, trade-marks, technology, copyrights andinternational tax planning

• International equipment leasing

11:00-13:00

Beneficial Ownership Concept • Definition of beneficial owner• Entitlement of benefits• Recent Cases• Practical Ideas

13:00 Lunch

14:00-15:45

Non-discriminationMFN clause

• Non-discrimination and taxation of business profits

• Analysis of Protocol of OECD Model Tax Treaty

• Practical Cases• Most-favored nation treatment

16:00-18:00

Obstacles to Tax PlanningAnti-abuse provisions

• Thin-cap Rules• CFC Rules• Anti-Tax-Haven Rules• Place of Effective Management• GAAR

19:00 Cultural program

Program - Day 4Program - Day 4TimeTime TopicTopic DescriptionDescription

09:00-10:45 Introduction to transfer pricing

• Importance of transfer pricing• Associated enterprises• Arm’s length principle

11:00-13:00 Determining Arm’s Length Price

Transfer pricing methods

• Comparable Uncontrolled Price• Cost-plus method• Resale-price method• Profit-split method• Transactional Net Margin Method• Other methods

13:00 Lunch

14:00-15:45 Transfer Pricing Planning • Choice of method and supporting the choice,

• Retrieving information and estimation of price

16:00-17:00

Bilateral Investment Treaties and their relevance for

taxation

• What are BITs- their nature and structure

• How are they connected to DTT- comparison

• Their relevance for taxation• State responsibility for tax matters under

BITs

17:00-18:00 Country Presentations • International Tax Rules in Selected Countries

• Participants can indicate interest in the country systems that they would like to hear about

18:00 Networking Reception by International Consulting

Company



Morning: Introduction to EU Tax Law:

- European taxation: harmonization and coordination- History and terminology- Objectives and means- Competencies- EC Law: domestic law- EC legislation and other tools- EC treaty and taxation

Afternoon Case Study Workshops Participants are divided into groups Cases are distributed among teams Cases will focus on the following areas:

− Taxation of Services− Structuring of Holding Company− Structuring of Private Equity Fund− Permanent Establishment− Passive Income− Tax Planning− Transfer Pricing


Cultural ProgramCultural ProgramDay 6, 7


Celebration of Croatia’s Joining Celebration of Croatia’s Joining into the European Unioninto the European Union

Midnight from 30th – 1st of July


Who are the lecturersWho are the lecturers

Tomas Balco (JUDr., LL.M., ACCA) is an internationally well-known and recognized tax expert with over 12 years of international tax experience in both private and public sectors in different countries and continents.

Tomas has practical experience in international taxation ranging from tax consulting and international tax structuring for multinational enterprises, investment funds and holding companies to assisting and consulting governments on tax reform and tax harmonization issues as well as on behalf of government negotiating and interpreting the double tax agreements.

Tomas Balco works as Associate professor at KIMEP and Director of Central Asian Tax Research Center and has relevant lecturing experience in various executive courses delivered for leading professional qualifications (ACCA, ADIT, etc.), Big 4 executive courses as well as for the leading educational institutes specialized on executive courses and international taxation – such as – BPP International, IBFD International Tax Academy, European Law Academy (ERA) in Trier as well as leading Universities.

Tomas is an active member of IFA (International Fiscal Association) as well as a Chair of Tax Working Group of American Chamber of Commerce in Kazakhstan and member of Subcommittee (Tax Treaty Negotiation Manual) of UN Committee of International Tax Experts.


Vladimir Tyutyuryukov is CIS tax expert with 10 years of experience in industry, consulting and academics. He holds specialist and Candidate of Sciences degrees in economics and is member of International Fiscal Association (IFA).

Vladimir worked in the tax department of RAO UESR, a largest Russian power company of the time, dealing with the analysis of draft legislation, tax consulting of the subsidiaries and tax accounting. Later he joined tax practice of Big4 company in Russia, performing and then leading various tax projects for large Russian and international companies (mainly from the energy & resources industry), including tax review, due diligence projects, tax and transfer pricing consulting regarding cross-border transactions and corporate restructuring, and led in-house seminars and roundtable for clients.

Since 2004 he teaches in different universities, mainly in Russian State Tax Academy and – from January 2011 – in KIMEP University, where he is also co-leading Central Asian Tax Research Center.. He published more than 30 articles on tax and economics in Kazakhstan, Russia and abroad; he is also author of a university textbook “International Standards of Audit”. He regularly participates in the Russian, Kazakhstani and international conferences on taxation and is member of International Fiscal Association.


Marco Greggi is Associate Professor of Taxation law at the Department of Law, University of Ferrara, Italy, and he also lectures at the School of Finance and Economics, Ministry of Finance, Italy. He is a member of the Ph.D board in European Law of the University of Ferrara, Rovigo Campus, of the European Tax Studies Review and of the European School of Advanced Tax Studies in Bologna. Before entering Academia, he was admitted to the Italian Bar, was appointed as Tax Inspector at the Ministry of Finance and acted as external advisor for a number of private corporations and public bodies in Italy including the Ministry of Finance where he regularly lectured on jurisprudence and case law development.

Igor Loncarevic is partner in charge of both Serbian and Montenegrin tax practice. He has more than ten years of extensive experience in tax advisory services including corporate income tax, international taxation, cross border tax structuring, pre- and post privatization tax optimization, M&A tax and value added tax for various foreign clients in Serbia and Montenegro.

Igor has worked in KPMG London M&A Tax Department and also has experience working in Germany and Russia. His main responsibilities encompass establishing and maintaining client relationship and being responsible for quality of deliverables provided.

Igor has experience with performing tax due diligence projects for numerous foreign investors and has been an instructor on international tax courses within KPMG CEE region. Igor is also an author of a number of articles on tax law in business magazines in Serbia.


Karmen Demsar is a partner with LeitnerLeitner and a member of board of tax advisors with Slovenian Institute of Auditors.

She has more than ten years of experience in tax advisory services including Slovenian and international tax law, corporate taxation and taxation of expatriates.

Karmr also has experience working as tax advisor, auditor and lecturer of corporate tax law for certified auditors with Slovenian Institute of Auditors.


Blaz Pate (LL.M.) is an internationally well-known and recognized expert in international and EU tax law.

Blaz Pate has practical experience in international taxation ranging from tax consulting and international tax structuring for multinational enterprises and especially in the filed of M&A transactions. He is regularly publishing books and articles. He is also a regular lecturer at the Slovenian Institute of Auditors.

Blaz Pate finished the LL.M. in International Tax Law (Vienna). Blaz Pate was working at LeitnerLeitner. Currently he works as an attorney-at-law.


Jure Mercinais a lawyer (The Faculty of law in Ljubljana) with bar exam and works in Slovenia in the Law firm Blaž Pate Ltd. as an attorney candidate.

Jure has practical experience in domestic and international taxation with focus on corporate and personal income taxes (direct taxation).His core competences are in the area of M&A, tax planning and tax structuring. Besides taxationhis main specialties are corporate law and labour law. Jure is also an author of a number of articles on taxationin business magazines in Slovenia.

Jure is a member of IFA (International Fiscal Association) and Slovenian Bar association.


Irena Alajbeg (mag.iur) has 8 year experience in international taxation –both public and private sector. She worked at Croatian Ministry of Finance as a member of tax treaty negotiation team and later as a Senior Consultant in Ernst & Young Croatia where here main responsibilities were connected to expatriate taxation.

She also lectured at numerous executive courses on tax treaties and taxation of employment income.

Currently she is engaged as a Head of International Agreements Department at State Office for Trade Policy and is in charge for investment and economic cooperation agreements as well as investor-sate dispute settlement.

She is attending PhD program in International Public and Private law at University is Zagreb where her focus is on international investment law and state responsibility under international public law.


Summer School VenueSummer School VenueCroatian International Tax Summer School will be held at Admiral Hotel, Opatija.

Located just a short walk from the city center, Hotel Admiral Opatija is situated right on the Adriatic Sea and Lungomare coastal promenade. The hotel amenities are excellent. Spend a day at the outdoor pool with sunbathing area raised above the sea and take in some marvelous views.

The SPA zone includes an indoor swimming pool, whirlpools, saunas and a fitness center. Sample regional dishes and wine at the a la carte restaurant's summer terrace.

Hotel agreed to work with us as a partner in organizing this event and offered a special conference package rate for the participants of Croatian International Tax Summer School in the amount of Euro 76 (for single rooms) and Euro 62 (for double rooms). This includes accommodation, use of internet, breakfast, coffee breaks and lunch.

Staying in the same hotel will facilitate punctuality and also proper logistics for you.

Hotel Admiral Contact Information:http://www.liburnia.hr/en/hotel-admiralTel: +385 (0)51 710 444Fax:+385 (0)51 710 399Email: [email protected]

Countries invited to participateCountries invited to participate

• SloveniaSlovenia

• AlbaniaAlbania

• FranceFrance

• TurkeyTurkey

• GreeceGreece

• Bosnia-HerzegovinaBosnia-Herzegovina

• MoroccoMorocco

• SlovakiaSlovakia

• Czech RepublicCzech Republic

• IsraelIsrael

• PolandPoland

• ItalyItaly

• SpainSpain

• TunisiaTunisia

• CroatiaCroatia

• MonacoMonaco

• MaltaMalta

• CyprusCyprus

• AlgeriaAlgeria

• UkraineUkraine

• BulgariaBulgaria

• RomaniaRomania

• KazakhstanKazakhstan

• RussiaRussia

Participation feeParticipation feeParticipation fee is 1000 EURO for invited countries (see above for list of countries).

Participation fee for representatives of other countries (not included into the list) is 2000 EURO.

In addition to early bird discount (10%) we offer additional noncumulative discount for members of partner organizations (IBFD Members and Alumni, AmCham, ANK, ACCA) 10 %.

Early Bird Discount - apply before 5th June 2013 to qualify for early bird discount of 10% (applicable to all countries).

Participation fee covers training sessions, materials (in hard copy and electronic format), coffee breaks, lunches and receptions.Accommodation, travel and other personal expenses are not covered.

We aim to use the surplus of this event to assist those from underprivileged countries and who cannot afford to participate – we will provide both fee waivers and financial support for travel and accommodation for selected participants (usually graduate or postgraduate students studying international taxation in Mediterranean Countries without the financial means to afford the participation).

The full time students, full time academics or participants from other countries that believe they should qualify for a special price or partial/full partial waiver, should contact the program coordinators a request a discount..


Sponsorship ProposalSponsorship Proposal

Sponsorship Benefits:

- Publicity: your sponsorship will be supported through integrated marketing, which includes placement of company’s logo into summer school brochure, email campaigns and during the seminar itself

- Special participation discounts as follows:a) Gold Sponsorship – 4 participants

registered – 10% discount for each participant cumulative – 40% discount

b) Silver Sponsorship– 3 participants (30% discount)

c) Bronze Sponsorship – 2 participants (30% discount)


Enrollment processEnrollment processTo register please send us an email to [email protected] before 21st June 2013.

Subsequently you will be asked to complete registration form that we will send you via email.

Please also check whether you need a visa to enter Croatia (which is not member of Schengen area). If it is needed, we advise you to arrange for it 2-3 weeks in advance.

Summer School Co-coordinator:Meruyert AssilovaPhone: +7 702 2725522

Academic Co-coordinator:Vladimir TyutyuryukovPhone: +7 701 848 2017


Welcome to Central Asian Tax Welcome to Central Asian Tax Research CenterResearch Center

The Central Asian Tax Research Center (CATRC) is a specialized academic unit engaged in tax-related research and hosted by the School of Law at Kazakhstan Institute of Management, Economics and Strategic Research (KIMEP).

CATRC members perform tax-related research and analytical work, mainly focused on Kazakhstan and Central Asian countries, and to a certain extent on CIS and Eastern/Central European countries.

CATRC strives to fill an untapped niche of taxation education in Central Asia and seeks to position itself as a tax research and knowledge hub for Central Asia, as well as a place for professional development and networking. CATRC also serves as a consulting think tank and knowledge hub for corporate and government entities.


Welcome to CroatiaWelcome to Croatia

Croatia is a unitary democratic parliamentary republic in Europe at the crossroads of Central Europe, the Balkans and the Mediterranean. Its capital and largest city is Zagreb

The service sector dominates Croatia’s economy, followed by the industrial sector and agriculture. Tourism is significant source of revenue during the summer with Croatia ranked the 18th most popular tourist destination in the world.

Croatia signed the EU Accession Treaty in December 2011 and ratified the Treaty in January, 2012. Croatia will become a member after all 27 EU members ratify the treaty, with a target date of July 2013.


MediterraneanMediterranean

The Mediterranean, which literally means the “sea between lands”, offers favorable environmental conditions, such as climate, biological diversity and natural resources.

The Mediterranean Sea is the largest of the semi-enclosed European seas. It is surrounded by 18 countries and has shores on three continents (Europe, Africa and Asia) with a combined population of 129 million people in the catchment draining into sea, and sharing a coastline of 46 000 km.

It is one of the leading tourist areas in the world, hosting 100 million visitors every year


invitation to international tax summer school

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