Substance: Aligning international tax planning with today's business realities comes at a moment when we are facing the most important global economic challenges in recent history. The current downturn has caused policy makers in various countries to question tax planning by multinational company groups from a mere “morality” perspective, considering the negative consequences for government budgets, which are under ever greater pressure. It is likely that legislation will be passed at various levels, allowing tax authorities around the globe to more effectively challenge tax structures which are perceived as artificial. Tax planning without appropriate economic substance is therefore under big pressure.

The book addresses exactly this need for the proper monitoring of economic substance in the context of corporate structures (for the tax residency of companies and beneficial ownership of income flows) and in the context of operating models (for the transfer pricing of goods, services and intangibles among entities marked by some form of economic solidarity). It also considers the domestic tax rules in 44 countries around the globe and reviews how they interact with the OECD rules (double tax treaties, transfer pricing guidelines) and EU law.

Substance: Aligning international tax planning with today's business realities can provide guidance to taxpayers everywhere to review whether their tax strategy is sufficiently solid to deal with increased scrutiny by tax authorities.

Order Substance: Aligning international tax planning with today's business realities, by Axel Smits and Isabel Verlinden   Price: €175 plus shipping Media: Book Publication date: 22 June 2009 PwC orders You will need to provide your GUID and password to access the order form.

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Axel Smits

Partner, International tax services

Axel Smits is a tax partner with PwC in Belgium and heads up the Belgium international tax services team. He holds a law degree as well as additional qualifications in taxation, accountancy and finance. He is a chartered tax consultant under Belgian law (member of IAB/IEC) and a member of the International Fiscal Association (IFA).

Axel has more than 18 years of experience and frequently travels around the world for his clients where he regularly encounters issues regarding intellectual property rights (IP rights). He has developed particular expertise on IP rights throughout their life cycle and is recognised as an expert in the global PwC network.

He co-authored Mastering the intellectual property rights life cycle: A global perspective on the tax-efficient management of IP rights which looks at intellectual property throughout its life cycle, from a tax, legal and managerial angle. He further authored or contributed to various other publications which deal with the tax, legal or financial dimension of IP rights.

Additional
publications
by the author

Isabel Verlinden

Partner and European transfer pricing leader

With first-hand knowledge of the transfer pricing challenges faced by companies operating across the globe, derived from over 20 years of experience working both in Brussels and Washington DC, for PwC (and its legacy firms), she co-ordinates worldwide transfer pricing and/or intellectual property projects for some of the world’s largest multinational groups.

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 is also listed in the ‘Best of the Best’ Expert Guide containing the world’s 25 most nominated experts in their area of competence by in-house counsels and peers. She co-authored Mastering the intellectual property rights life cycle: A global perspective on the tax-efficient management of IP rights.

She actively contributes to thought leadership initiatives in the area of transfer pricing as one of the fifteen Business Members of the European Commission’s Joint EU Transfer Pricing Forum and as an invitee to Specialist Business Expert Group Meetings at the OECD (Organisation for Economic Co-Operation and Development). She is a prolific writer for international tax and business periodicals and has authored or co-authored over 70 articles and books to date. She is a member of the International Fiscal Association (IFA) and a chartered tax consultant under Belgian law (member of IAB/IEC).

She holds a degree in Commercial and Financial Economics (Major in Accountancy), a degree in Commercial and Financial Economics (Major in Taxation) and a degree in Applied Economics (Major in International Business Affairs).