Milton Grundy
Chairman, ITPA
Richard Hay
Ronen Palan
Jason Romer
Felicity Cullen Q.C.
Anthony Markham and Dalila Ver Elst
Niklas Schmidt
Jonathan Conder
Derek Sambrook
Geoffrey Simpson

Programme
Sunday, 9 June
15.00 Registration
18.30 Welcome Reception

Monday, 10 June
09.00 Tax Havens: For – Richard Hay
Increase world economic growth; lead in regulatory standards
China in defence of offshore centres
World economy without off shore centres
Competition positive and liberalising
Tax Havens: Against – Ronen Palan
International correlation between taxation and GDP/Capita ratios
Gap between rich and poor
Massive capital transfer from developing countries through off shore jurisdictions
Location for the shadow banking system at the heart of the financial crisis
9.40 Image Rights – Jason Romer
Where to register and how to exploit them
The rationale
What uses do we see for this legislation?
What can you register?
How do you register?
The infringement question?
Lessons in structuring
10.20 Coffee
10.50 Mediation in Tax Disputes – Felicity Cullen Q.C.
Developments in the United Kingdom and elsewhere
Context – the UK’s Tax Litigation and Settlement Strategy
Mediation as a form of Alternative Dispute Resolution
The nature and potential benefi ts of mediation
Cases which might be suitable and cases which might be unsuitable for mediation
Public law limitations on HMRC’s ability to compromise
Practical Developments
11.30 Ethics and Tax Planning – Anthony Markham and Dalila Ver Elst
Why is it not enough to respect the law?
What is aggressive tax planning, when is it immoral, and what extra-legal sanctions are imposed?
To what extent should all parties consider the social and economic
consequences of international tax and regulatory planning?
The level of public debate
A toolkit for addressing these questions, including how to guide clients wisely, avoid tabloid lynching, defend your profession at dinner parties and sleep soundly at night
12.10 Pre-lunch drinks, followed by set lunch
14.30 Discussion Session I
15.15 Tea
15.45 Discussion Session II
16.30 Close of Day One
18.30 Reception
Tuesday, 11 June

09.00
Immovable Property and Double Taxation Treaties – Niklas Schmidt
Planning opportunities
The defi nition of immovable property in art. 6(2) of the OECD-MC
Exploration and exploitation rights
Usufructs
Mineral royalties
Means of transportation
Shares in real estate companies
The use (art. 6 of the OECD-MC) versus the alienation (art. 13 of the OECD-MC) of immovable property
09.40 Offshore Trusts – Jonathan Conder
Managing the practical issues
Investment portfolios
Trading companies
Real property
“Toys”
Disputes
Tax and regulatory changes
10.20 Coffee
10.50 Understanding the South American Client – Derek Sambrook
Objectives and needs
A backward glance
From solitude to fortitude
Two languages: one purpose
Culture of confianza
11.30 International Structuring Using UK Entities – Geoffrey Simpson
What UK arrangements used in the past still work today?
How have these UK solutions substantially improved in recent years?
When do UK companies get tax treaty residence certificates?
What are the various routes for re-domiciling companies into the UK?
What new UK entities exist and how are these now being used?
12.10 Pre-lunch drinks, followed by set lunch
14.30 Discussion Session I
15.15 Tea
15.45 Discussion Session II
16.30 Close of Meeting