How US GILTI and Global Unilateral Measures are Impacting the Digital Tax Discussion:

Policy, Politics and Practical Implications of Taxing the Digitalized Economy

Overview

With no global consensus on the taxation of the digitalized economy to date, several jurisdictions, including India, France, and the U.K., have considered, proposed, or adopted unilateral measures to address the digital tax issues. In addition, increasing global attention has been given to a minimum tax proposal modeled in part on the U.S. GILTI provisions.

Our panel will provide insights into the politics and policy considerations that underlie the various unilateral measures, as well as any future challenges in developing a consistent global standard in light of the unilateral actions.

All attendees will receive a Special IFA Edition copy of the Bloomberg Tax Transfer Pricing Forum on Taxation of the Digital Economy.

Details

Tuesday, 10 September 2019

16:00 – 17:30 (4:00 PM – 5:30 PM)

IFA 2019 London

Queen Elizabeth Hall

Southbank Centre

Belvedere Road, London

Speakers

Robert Stack
Robert Stack, Managing Director, International Tax, Deloitte Tax LLP

In Deloitte’s Washington National Tax international tax practice, Bob Stack advises U.S. companies on a full range of international tax issues and collaborates with Deloitte’s global member firms on international tax developments and initiatives, including those from the OECD. Until January 2017, he was the Deputy Assistant Secretary for International Tax Affairs in the Office of Tax Policy at the U.S. Department of the Treasury.

During his tenure at Treasury, Bob led the U.S. efforts with respect to BEPS issues particular to the financial services industry around interest expense limitations, and in that regard worked closely with Saul Rosen of Citibank. He was also actively engaged in interactions with the financial services industry around both FATCA and the regulations under Section 385.

Bob was the official representative of the Obama administration for international tax policy and represented the U.S. government at the OECD, where he was involved in all aspects of the BEPS initiative. Prior to joining Treasury, Mr. Stack had over 26 years of experience in international tax matters, representing both corporations and individuals.

Annabelle Mirabaud
Annabelle Bailleul-Mirabaud, Partner, CMS Francis Lefebvre Avocats

Annabelle Bailleul-Mirabaud specializes in international taxation with an expertise on permanent establishments, CFC and substance issues, assisting leading multinational groups in tax audits and litigation.

She also assists multinational groups on a day-to-day basis in relation to international taxation matters including transfer pricing and taxation of cross-border flows. Annabelle has a significant experience in the structuring and implementation of worldwide incentive plans.

She joined CMS Francis Lefebvre Avocats in 2003 after several months with CMS Francis Lefebvre Avocats, New York. She is one of the authors of Tax Management Portfolio Business Operations in France.

Liz Chien
Liz Chien, VP of Global Tax and Chief Tax Counsel, Ripple Labs

Liz Chien is responsible for all aspects of taxation at Ripple Labs, an innovative distributed ledger software company that is enabling the world to move value like it moves information today. She joined Ripple from General Electric, where she was the Global Tax Director and Senior International Tax Counsel for GE’s industrial software business, GE Digital.

Prior to GE, she served as a policy advisor at the Organisation for Economic Cooperation and Development (OECD), where she worked on international tax reform relating to the digital economy in Action 1 of the OECD BEPS Project. Liz is the former Asia-Pacific Head of Tax for Google and was a Tax Director at Softbank Group International. Prior to Google, she was an attorney with Baker & McKenzie LLP. Liz was recently appointed to the State of California’s Blockchain Technology Working Group.

Liz received her Bachelor’s and Master’s degrees from Stanford University and her Juris Doctor from the University of California, Hastings College of the Law.

Andrew Cousins

Andrew Cousins, Director, Transfer Pricing, Duff & Phelps

Andrew Cousins is an international tax practitioner in the Duff & Phelps Transfer Pricing practice, with more than 20 years of cross-border experience in private practice, industry and in government. He brings a comprehensive regulatory, commercial and advisory perspective to the fields of transfer pricing and business restructuring, with a focus on practical implementation. Before joining Duff & Phelps Andrew was Deputy Comptroller of Taxes in the Jersey tax authority, acting as competent authority for all of Jersey’s international tax agreements. He also served as Jersey’s delegate to the Global Forum on Transparency and Exchange of Information for Tax Purposes, as well as representing Jersey at the OECD’s Global Forums for Transfer Pricing and for Tax Treaties. Andrew spent eight years in industry as a global head of transfer pricing in two FTSE 100 FMCG multinationals.

Andrew is a graduate of Oxford University and is a fellow of the Institute of Chartered Accountants in England and Wales. He qualified as a chartered accountant at Deloitte before focusing on transfer pricing at Ernst & Young, where he was a member of its Tax Effective Supply Chain Management team.

Rahul Mitra
Rahul Mitra, Partner, Dhruva Advisors LLP, India

Rahul K. Mitra is currently a Partner at Dhruva Advisors LLP, India. Prior to joining Dhruva Advisors, he was the National Head of Transfer Pricing & BEPS for KPMG in India and, before then was the National Leader of PwC India’s transfer pricing practice between 2010 and 2014. Rahul was a Partner in the tax & regulatory services practice of PwC India between April 1999 and February 2015.

Rahul has over 22 years of experience in handling taxation & regulatory matters in India. He specializes in transfer pricing, particularly inbound & outbound planning assignments, and advises on profit/cash repatriation planning, value chain transformation or supply chain management projects, profit attribution to permanent establishments, etc. Rahul independently handles litigation for top companies at the level of the Income Tax Tribunals. At least 50 of the cases independently argued by Rahul have been reported in leading tax journals of India. Some of the major wins of Rahul before the Tax Tribunals in transfer pricing matters have set precedents, both in India and globally.

Rahul has been consistently rated among the leading transfer pricing professionals & tax litigators in the world, by Euromoney and International Tax Review, since 2010.

Rahul has handled several APAs in India, involving clients from across industries, and also covering complex transactions, e.g. industrial franchise fees/variable royalties under non-integrated principal structures, contract R&D service provider model, distribution models with related marketing intangible issues, financial transactions, profit split models for royalties, etc.

Rahul is a longtime Member of the Bloomberg Tax Transfer Pricing Forum Advisory Board. He has been a visiting faculty of the National Law School teaching classes on transfer pricing & international tax treaties.

Rahul was the Country Reporter on the topic, “Non Discrimination in international tax matters”, for the IFA Congress held in Brussels in 2008. Rahul was invited by the OECD to speak in the 2012 Paris roundtable conference on developing countries’ perspective on APAs.

Julie Joy
Moderator: Julie Joy, Senior Fellow, Bloomberg Tax

Julie is a former director in the transfer pricing practice of Deloitte Tax LLP, most recently managing the Carolinas transfer pricing practice. She has extensive experience assisting clients with international and multistate projects involving transfer pricing planning, documentation, and audit defense. Julie has 25 years of public accounting experience, of which 18 were devoted exclusively to transfer pricing.

Julie received her BBA in Accounting from the University of Wisconsin-Eau Claire and her MST from American University.