March 19, Viktoriya Fomenko, Partner and Head of Тax and Customs practice INTEGRITES, spoke about working with non-residents in the era of BEPS at the Finance Leaders Forum.
Viktoriya Fomenko’s presentation was divided into three main parts:
- Agreements on avoidance of double taxation.
- Permanent representative.
- Work with offshore companies.
The first part was devoted to the criteria for the application of agreements on the avoidance of double taxation. So, in particular, Viktoriya focused on the criteria for the beneficial owner and reviewed the approaches of the tax authorities and current practice. Additionally, special attention was paid to the MLI convention, what it affects and what additional obstacles will arise for the application of agreements on avoidance of double taxation in connection with the ratification of the MLI convention.
During the second part, audience found out about the measures to counter the artificial avoidance of a permanent establishment imposed by the MLI Convention, and dismantled the position of the court and DFS in the case of South Mining Plant OJSC.
In conclusion, Viktoriya Fomenko analyzed the restrictions on working with offshore companies, namely, she commented on the EU black and gray lists, the substance requirements, and highlighted the innovations in transfer pricing rules.
LEADERS FORUM – is the third practical event for financial managers of large and medium-sized companies from all sectors of the economy, which covers the most pressing issues related to the problem of raising funds, effective cash management, taxes and cost control, with the development of financial strategy and effective control key business processes of the company.
For the full text of presentation, please refer to the link.