March 30, 2011 Akin Gump Strauss Hauer & Feld LLP in association with International Tax and Investment Center holds a seminar

"Changes to the Application of International Tax Treaties"

Date: Wednesday 30th March 2011 

Time: 9:30 - 13:00

Venue: Ararat Park Hyatt Moscow, 4 Neglinnaya Street Moscow, 109012 Russian Federation 

The speakers will give an overview on:

Changes to the Application of International Tax Treaties. Implications for international tax structures

•          Overview of typical tax-driven holding structures for Russian operating companies

•          Illustration of tax cost in such structures if the changes to Russia’s beneficial ownership test mean that the foreign holding company no longer qualifies

•          Discussion of anti-abuse legislation in other jurisdictions, with a specific focus on Switzerland

•          Speculative strategies for risk mitigation

•          Further structuring considerations and alternatives

New trend in Russian tax policy: limitation of tax treaty benefits
Government perspective – overview from a  senior State Duma / Ministry of Finance representative

•          Potential introduction of beneficial owner test in Russia

•          Unjustified tax benefit concept and international tax treaties

•          Treaty shopping

•          Effective place of management test

•          Permanent establishment considerations

•          Revision of commonly used tax structures in light of this new trend; discussion of potential alternative solutions

The legal framework of the interpretation of tax treaties and its role in understanding the scope of anti-abuse measures in an international context, a Dutch perspective

•          Treaty interpretation in general

•          Dutch national abuse measures

•          Anti-abuse measures often seen in Dutch tax treaties

•          Conflicts between national anti-abuse measures and treaty provisions/anti-abuse measures

To obtain further information or RSVP for this event, please contact Julia Osipova at josipova@akingump.com or +7 495 783 7700.  Please note that number of places is limited.