Tax Law Summer School 2014

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CATÓLICA GLOBAL SCHOOL OF LAW CUTTING EDGE LEGAL EDUCATION


2014 1

23-27 jun un ne n

“I had a fantastic time in Lisbon. The speakers were of great quality, both in terms of experience - which they generously shared through real life examples - and presentation skills. I learned a great deal from other students, as well, as many were specialists in their field. In short, signing up was the right professional decision!”

Alixe Leclercq HK University – Asian Institute for International Financial Law | HongKong


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CATÓLICA GLOBAL SCHOOL OF LAW CUTTING EDGE LEGAL EDUCATION

In June 2014, Católica Global School of Law will be offering the third edition of its Tax Summer School comprising two programmes, on Value-Added Tax and Transfer Pricing. Católica’s Tax Summer School programmes are fully lectured in English by leading international academics and professionals and are aimed at students and practitioners willing to explore two of the most fascinating and complex areas of modern taxation. All classes are held at the Campus of the Catholic University, in Lisbon. The VAT Programme starts with a one-day introduction to the fundamental concepts of value-added taxation. In the following days, sessions will be held on some of the most important topics of EU VAT. Similarly, the Transfer Pricing Programme starts with a one-day intensive introduction to the fundamentals of Transfer Pricing, while in the following days critical topics of transfer pricing will be covered. Both programmes run from Monday to Friday, the Transfer Pricing sessions being held in the morning, the VAT sessions in the aernoon.

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The programmes may thus be aended separately or simultaneously, with a special discount.


TAX LAW SUMMER SCHOOL

PROGRAMMES Welcome Dinner June 23, 20:00

TRANSFER PRICING

09 9:0 00 13 3:3 30 3

PROGRAMME DIRECTOR JOÃO GAMA

June 23 Dinner Party June 27, 20:00

Transfer Pricing Fundamentals

09:00-13:30

H. DAVID ROSENBLOOM (New York University)

June 24 “In VAT Summer School 2013 I had the opportunity to witness the sharing of information which is essential to my work, transmied by experienced professionals who deal with this tax in a daily basis. Its scope and international approach were also key factors to choose this course, which has revealed to be an important tool in monitoring the evolution of the themes of VAT.”

OECD Recent Developments

09:00-11:00

GIANMARCO COTTANI (Italian Revenue Agency / University of Jönköping),

Recent US Case Law

11:30-12:30

H. DAVID ROSENBLOOM (New York University)

Recent European Case Law

12:30-13:30

GIANMARCO COTTANI (Italian Revenue Agency / University of Jönköping)

June 25 Transfer Pricing in Brazil

09:00-11:00

LUÍS EDUARDO SCHOUERI (Universidade de São Paulo)

Business Transformation and Permanent Establishments

11:30-13:30

JAIME ESTEVES & LEENDERT VERSCHOOR (PwC)

June 26 Intangibles and Transfer Pricing

09:00-11:00

Strategy, Management and Documentation: the view from a global company - the case of Syngenta 11:30-13:30 ISABEL VERLINDEN (PwC / Joint Transfer Pricing Forum)

Isabel Vieira dos Reis Garrigues | Portugal

June 27 Advance Pricing Agreements

09:00-10:00

JOÃO GAMA (Católica Global School of Law)

Transfer Pricing Litigation C. DAVID SWENSON (PwC / Georgetown University)

10:30-13:30


VALUE ADDED TAX

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14 4:3 30 19 9:0 00 0

PROGRAMME DIRECTOR SÉRGIO VASQUES

FEES

June 23 VAT Fundamentals

14:30-19:00

BEN TERRA (University of Lund / Católica Global School of Law)

• Professionals: €990 • Católica's LL.M. partners

June 24 VAT, Mergers & Acquisitions

/ Católica alumni: €890 14:30-16:30

• Students from other schools: €700 • Católica students / TLP and Law

17:00-19:00

Schools Global League students: €600 • Early bird rate (30 April): €600

STEFAN MAUNZ (KMLZ)

Recent ECJ Case Law on VAT

BEN TERRA (University of Lund / Católica Global School of Law)

June 25 VAT in Developing Countries

14:30-16:30

SIJBREN CNOSSEN (Emm. Prof. University of Rotterdam)

Fixed Establishment

For each programme (separately)

17:00-19:00

Fees for both programmes (simultaneously) • Professionals: €1790 • Católica's LL.M. partners

/ Católica alumni: €1490

HERMAN VAN KESTEREN (University of Tilburg / PwC)

• Students from other schools: €1190 • Católica students / TLP and Law

June 26

Schools Global League students: €990 • Early bird rate (30 April): €990

Digital Transformation: VAT and Electronic Services

14:30-16:30

MICHAELA MERZ (PwC)

VAT Grouping

17:00-19:00

TRUDY PERIÉ (Loyens & Loeff)

REGISTRATIOn

June 27

catolicatax@ucp.pt

Overhead Costs and VAT Deductability

14:30-16:30

DENNIS JENSEN (University of Aarhus)

VAT Treatment of Public Bodies OSKAR HENKOW (University of Lund)

17:00-19:00

LOCATIOn All classes are held at the Campus of the Catholic University, Lisbon. http://goo.gl/maps/y6AkO


Ben Terra

World top Faculty Ben Terra “This Tax Summer School has been an amazing experience. I would recommend all tax professionals to aend this week, not only to broaden your knowledge but also for building your network with valuable contacts. As the lecturers are from all over the world and from different areas, they bring a great knowledge and value this Summer School.”

Ben Terra studied international law at the University of Amsterdam and taxation at the University of Leiden. He was head of the post-graduate training in VAT, customs and excises at the Ministry of Finance in the Hague, professor of law at the University of Leiden and visiting professor at the Universities of Florida in Gainesville, of Sydney in Australia, the Gmimo University in Moscow and the Anton the Kam University in Surinam. Ben was head of the global indirect tax practice of Ernst & Young until 2002 and member of the board of Ernst & Young tax advisors, the Netherlands. Ben has an honorary doctorate in economics from the University of Lund and has published numerous articles and books on indirect taxation. As a consultant of the OECD, the European Commission and IMF, he has been involved in re-organizing tax departments, drafting law and policy and training tax officials in various countries including Indonesia, the Dutch Antilles, Aruba, the Czech Republic, the Slovak Republic, Albania, the Ukraine, the Baltic States and the CIS, Surinam and Bangladesh. At present he teaches indirect tax and European tax law at the University of Amsterdam and the University of Lund. Ben is also lecturing at the University of Vienna, the University of Neuchâtel and the University of Münster.

Ellen de Jong W. P. Carey & Co . B.V. | The Netherlands

David Swenson David Swenson is a principal at PricewaterhouseCoopers in the Washington National Tax Services practice, Global Leader of PwC’s Tax Controversy and Dispute Resolution Network, and is resident in the Washington, D.C. office. David is an Adjunct Professor at Georgetown University Law Center, where he has taught courses relating to international corporate income taxation continuously for 25 years. Following a prominent legal career spanning almost three decades, David brings to PwC a wealth of experience in advising multinational corporations on international tax matters and has substantial experience assisting companies in preventing, managing, and resolving tax audits and disputes. Over the years, David has participated in more than 250 tax controversies involving disputes between MNCs and the IRS, and more than two dozen other revenue authorities around the world. Many of these tax disputes were docketed in a U.S. court of law, proceeded to trial, and resulted in landmark judicial decisions for MNCs, and David also participated in several landmark tax cases


Dennis Jensen Dennis Ramsdahl Jensen has a Ph.D. degree in European VAT Law and is full-time Professor in Indirect Tax Law at Aarhus University, Denmark. His primary area of research is Indirect Tax Law with emphasis on European VAT Law. Dennis teaches VAT Law to students and professionals and is Director of study at the LL.M. in VAT and Indirect Taxes at Aarhus University. He has published extensively on Indirect Tax issues and hosted several seminars and conferences on Tax Law as well as been speaker and chairman at numerous national and international conferences.

Gianmarco Coani Giammarco Cottani is an International Tax Adviser to the Central Assessment Commissioner of Italy Revenue Agency, and is a Member of the Sub-Committee Group of the United Nations in charge of the Draft of the Practical Manual on TP for Developing Countries. Before joining the Agency, he worked as a Transfer Pricing Advisor in the Tax Treaty and Transfer Pricing Unit of the OECD, where he was involved in the introduction of the new Chapter IX of the OECD Guidelines. He received his degree in Law & Economics from LUISS

H. David Rosenbloom

Gianmarco Coani

Dennis Jensen

David Swenson

before the U.S. Supreme Court, including the Barclays Bank, Boeing, and Goodyear cases. David has been described as “one of the top five tax controversy experts in the United States,” and has also received recognition as: one of the Top 20 Leading Attorneys in the U.S. in the area of National Tax Litigation by “Chambers US”; one of the World’s Top 25 Transfer Pricing specialists by Euromoney’s; a First Tier Leading Individual in the areas of Tax Controversies and Cross-Border Structuring by the “International Tax Review”; and one of the Leading Corporate Tax Advisors in the World by the “Legal Experts Guide”. In addition, David received the Meritorious Service Certificate from the Treasury Department and the IRS. David received his ML.T., from Georgetown University Law School, where he was Associate Editor of “The Tax Lawyer”, and his J.D., with honors, and B.A., with distinction, from the University of Mississippi. David is a member of the ABA, the D.C. Bar, and has been admitted to practice before the U.S. Tax Court, the U.S. Court of Federal Claims, as well as numerous U.S. Federal Courts of Appeal, and the U.S. Supreme Court.

Rome University in 2003, an LL.M. in European and International Taxation from the European Tax College (Tilburg and Leuven) in 2005, and a Ph.D. in Corporate Taxation from LUISS Rome University in 2009. Giammarco is a member of the faculty of the International Tax Center of the University of Leiden for transfer pricing, the Course Coordinator of the Module “Transfer Pricing Rules in International Taxation” at the European Tax College of the University of Tilburg and he has been recently appointed Adjunct Professor in Fiscal Law at the Jönköping International Business School. He was the National Reporter for Italy during the 2011 IFA Congress held in Paris on the topic of cross-border restructuring.

H. David Rosenbloom H. David Rosenbloom is the Director of the International Tax Program at New York University School of Law and a member of Caplin & Drysdale, Chartered, a law firm he rejoined in 1981 after serving as International Tax Counsel and Director, Office of International Tax Affairs, in the U.S. Treasury Department from 1978 to 1981. Born in 1941, Mr. Rosenbloom graduated from Princeton University summa cum laude in 1962 and, after a year as a Fulbright Scholar at the University of Florence in Florence, Italy, attended Harvard Law School. He graduated magna cum laude in 1966 and was President of Volume 79 of the “Harvard Law Review”. Mr. Rosenbloom served as assistant to Ambassador Arthur Goldberg at the U.S. Mission to the United Nations and then as clerk to U.S. Supreme Court Justice Abe Fortas. A frequent speaker and author on tax subjects, Mr. Rosenbloom has taught international taxation and related subjects at Stanford, Columbia, the University of Pennsylvania, Harvard, and New York University Law Schools, and at educational institutions in Taipei, Mexico City, Milan, Bergamo,

Sydney, Mainz, Heidelberg, Rio de Janeiro, Pretoria, Melbourne, Vienna, and Neuchâtel. He has also served as Tax Policy Advisor for the U.S. Treasury, the OECD, AID, and the World Bank in Eastern Europe, the Former Soviet Union, Senegal, Malawi, and South Africa. In recent years he has served as an expert witness on international tax matters in the United States, New Zealand, Canada, Australia, and Norway.

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Herman is an Indirect Taxes Partner based in Amsterdam, the Netherlands with over 20 years experience and is currently responsible for knowledge management and litigation in the field of VAT. Herman received his Law Degree (Major in tax) at Leiden University and lectured European VAT at this university before transferring to Tilburg University in 2000, where he was appointed professor in the field of VAT in 2003. Since 2010 Hermanm is also guest-lecturer at Leuven University (Belgium). He is a Judge in the ‘s-Hertogenbosch Court of Appeals and in the ‘s-Gravenhage Court of first instance. Herman has often been a (guest) lecturer, both in the Netherlands and abroad, for academic scholars as well as for tax practitioners. He serves as lecturer in several international programmes. At the European Tax College (the joint LL.M. programme in “International and European Taxation” of the Universities of Tilburg and Leuven), he is responsible for the “Design and structure of consumption taxes” course. At the Leiden International Tax Center he is responsible for the course Value-Added Tax Law in the Adv. LL.M. in International Tax Law.

Isabel Verlinden Isabel Verlinden is PwC’s Transfer Pricing Leader for Europe, Middle-East, India & Africa, a Member of PwC’s Global Transfer Pricing leadership team and the Partner in charge of PwC Belgium’s International Tax and Transfer Pricing services. She appears in Euromoney/International Tax Review’s Guide to the World’s Leading Transfer Pricing Advisors, the Guide to the World’s Leading Tax Advisors and the Best of the Best Expert Guide, which identifies the top 25 best in the world by practice area, as elected by in-house counsel and peers. In her over 20 years experience she has built up smooth relationships with Competent Authorities across the globe as crystallized in many tax effective Advance Pricing Arrangements. She has (co-) authored over 90 articles and books to date (including “Mastering the IP Life Cycle” and “Substance: Aligning International Tax Planning with Today’s Business Realities”).

João Gama

Jaime Esteves

Isabel Verlinden

Herman van Kesteren

Herman van Kesteren

Isabel is one of the 16 elected Business Members at the European Commission’s Joint Transfer Pricing Forum. She actively contributes to thought leadership initiatives in the area of TP as invitee at Specialist Business Expert Group Meetings at the OECD. She is regularly invited to assist country policy makers (e.g. China to address Intangibles & TP). She will chair this year’s IFA Conference topic on “Profit Methods and the arm’s length principle” in Copenhagen.

Jaime Esteves Jaime Esteves is Partner of PwC Portugal and leads its Tax Department, with responsibility also for Angola and Cape Verde. He’s a specialist in Corporate Restructuring, International Tax Planning, Transfer Pricing and Wealthy Individuals. He is also a Tax Arbitror at CAAD and was the lawyer responsible for the EPSON tax case (ECJ). He is responsible for several tax courses and lectures at a number of Universities. He published several studies on taxation and collaborates regularly with leading media in tax matters.

João Gama João Gama teaches Tax Law at the Catholic University of Portugal, where he is the coordinator of Católica’s Post-Graduate Tax programme. He is the executive editor of the tax law review “Fiscalidade”. João Gama has published on a variety of tax law topics in Portugal and abroad Belgium, The Netherlands and Brazil). After graduating from law school (2000) and obtaining his masters degree (2004) at the University of Lisbon, he was a visiting researcher at NYU’s International Tax Programme in 2010 and in Georgetown University in 2013, and served as a political advisor to the President of the Portuguese Republic between 2011 and 2013. His Ph.D. dissertation, “The Global Word of The Taxman: Binding Rulings and APA’s” is expected in 2015. João lives in Lisbon with his wife and their five kids.


Leendert Verschoor leads the PwC Transfer Pricing Services Group in Portugal and is representing Portugal within PwC’s Global Transfer pricing Network. He started his professional activity in the area of taxation in the Netherlands. In 1999 he joined PwC in Portugal and became Partner in 2008. He specializes in areas related to international taxation of multinational companies, with 19 years of experience in these matters. Since 2002, devotes much of his time advising Portuguese subsidiaries of multinational groups and national groups with international presence in various sectors of activity with transfer pricing planning and transfer pricing documentation obligations. Leendert has a Degree in Business Economics from Erasmus University Rotterdam and a Degree in Tax Law from the University of Leiden, both in The Netherlands He is the author of the country section on Portuguese transfer pricing rules in the book “International Transfer pricing”, of the Portuguese section in the book “Mastering the IP Life Cycle and the book “Substance, Aligning international tax planning with today’s business realities” and wrote various articles about transfer pricing in economic newspapers and the International Transfer Pricing Journal.

Luís Eduardo Schoueri Luís Eduardo Schoueri holds the chair of Tax Law at the Law School of the University of São Paulo. He is partner of the law firm Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados, Vice President of the Brazilian Tax Law Institute (Instituto Brasileiro de Direito Tributário - IBDT), member of the Law Academy of São Paulo (Academia Paulista de Direito), and a Vice President of the São Paulo’s Commercial Association (Associação Comercial de São Paulo – ACSP).

Michaela Merz

Michael Tumpel

Luis Eduardo Schoueri

Leendert Verschoor

Leendert Verschoor

He obtained his master’s degree (1992) in law at the University of Munich under the guidance of Professor Klaus Vogel and achieved the Doctor’s and Free Professor’s degrees at the Law School of the University of São Paulo. Luís Eduardo is the author of several books and articles and studies published in Brazil and abroad, and has already lectured as Visiting Professor at the University of Florida, at the University Paris I Pantheon-Sorbonne and at the Vienna University of Economics and Business.

Michael Tumpel Michael Tumpel is a full-time Professor of Tax Management of the University of Linz, Austria and Director of a LL.M. in European Tax Law and of a MBA programme. He chairs the Indirect Tax Committee of the Austrian Chamber of Tax Advisers and is a Member of the Indirect Tax Committee of CFE. He is the author of many books and articles on VAT Law, European Tax Law and International Tax Law.

Michaela Merz Michaela is Indirect Taxes Partner at PwC and ITX Central Cluster Leader. Her expertise includes advising domestic and multinational companies in national and international VAT issues, advising on their worldwide VAT positions and leading worldwide project teams, structuring and implementation of principal and supply chain structures and an in-depth experience with global business structures, cross border transactions, outsourcing (Shared Service Centre) and restructuring. She is a specialist in e-biz and e-commerce.

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Sijbren Cnossen

Sérgio Vasques Trudy Perié

Oskar Henkow Stefan Maunz

Oskar Henkow Associate Professor (L.L.D.) Oskar Henkow is a teacher and researcher at Lund University, Sweden, exclusively focused on indirect taxes and the Value Added Tax (VAT) in particular. His thesis, published by Kluwer Law International in 2008, dealt with the VAT treatment of financial activities. In January 2013 he published a study on the VAT/GST treatment of public bodies, which is a legal comparative research of the EU system, the municipality VAT compensation funds and the GST treatment of public bodies on New Zealand. He is Programme Director of the Master’s Programme in European and International Tax Law, at Lund University, the Editor in Charge of the Case law and Legislative Development Sections of the World Journal of VAT/GST Law and an alternate member of the European Commission’s VAT Expert Group. He has published numerous articles dealing with VAT and is a regular teacher and presenter both in the private and public sectors. He also has an extensive experience as a tax consultant and advisor contracted by the IFC of the World Bank to provide advice on VAT legislation.

Sérgio Vasques Sérgio Vasques is a Tax Law Professor at the Catholic University of Portugal and Católica Global School of Law. He holds a Masters Degree and a Ph.D. in Tax Law and his main field of work is that of indirect taxation and environmental taxes. He has taken part in the drafting of the Portuguese Excise Duties Code, the reform of vehicle taxation and the introduction in Portugal of environmental charges on water and waste, among other projects. In recent years he has done extensive work in Africa, where he’s worked on the reform of VAT, excise duties and other indirect taxes. Sérgio held the post of Secretary of State for Tax Affairs of Portugal in the years 2009-2011.

Sijbren Cnossen Sijbren Cnossen is the Academic Partner of CPB Netherlands Bureau for Economic Policy Analysis, and Professor of Economics at the University of Pretoria. He is Emeritus Professor of Tax Law of Erasmus University Rotterdam and Emeritus Professor of Economics of the University of Maastricht. He has also held appointments at the Law Schools of the Universities of Harvard, New York and Florida, the College of Europe, and the Netherlands Institute for Advanced Studies. Professor Cnossen has been an advisor to the IMF, the World Bank, the OECD, the European Commission, and USAID. He has published widely on the economics of taxation, including the VAT, excise duties, personal and corporate income taxes, and the coordination of tax systems in common markets.

Stefan Maunz Dr. Stefan Maunz is a lawyer and certified tax consultant. With many years of experience in VAT and customs law, Stefan is a partner at KMLZ, a German law firm currently specializing in these areas. In addition, he has extensive experience working for international law firms in both Germany and the USA. He is a visiting lecturer at the University of Munich as well as a VAT Forum partner and Member of the VAT Expert Group initiated by the EU Commission.

Trudy Perié Trudy Perié (1962), tax lawyer, is a member of the VAT, customs and international trade practice group. She is heading the Amsterdam part of this practice group. She specialises in VAT, customs and excise duties, and is – inter alia – involved in real estate transactions, international trade, the finance sector (securitisations, holdings, investment funds), as well as the energy sector. She started her career as a VAT inspector with the Tax Authorities. During her employment at the Amsterdam office of one of the Big Four firms she also worked in New York. Trudy has written many articles on indirect taxation and is an editor of a biweekly legal magazine. She lectures on VAT, for example for the Dutch Association of Tax Advisers and is a guest lecturer at the University of Maastricht. She is an active member of the International Bar Association.


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“The Tax Law Summer School on VAT and Transfer Pricing in Lisbon are exceptional. The programmes are very well structured and taught by the best tax academics and professionals in these areas. The five day courses give you all the theoretical and practical background you need to work on these areas.”

LISBOn Lisbon provides the historical benefits of being in the place where the first step towards globalization was taken centuries ago. Lisbon has a vibrant modern ambiance, affordable living costs, and sits poised as the geographical and strategic bridge between Europe and the United States.

Miguel nicolas

USEFUL SITES

Ph.D. student in International and

www.visitlisboa.com www.lisbonwalker.com www.agendalx.pt www.cm-lisboa.pt www.visitportugal.com www.ipmuseus.pt

European Tax Law | University of Cergy-Pontoise | France


2014 Lisbo sb bon o

OTHER PROGRAMMES ROLLING APPLICATIONS 2014-2015 Advanced LL.M. in International Business Law LL.M. Law in a European and Global Context Global Ph.D. Programme Master in Tax Law (taught in Portuguese and in English)

Graduate Programme in Taxation (taught in Portuguese)

INFORMATION: catolicatax@ucp.pt www.catolicalaw.fd.lisboa.ucp.pt


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