Robert Gaut, the head of our UK tax practice and a partner in the London office of Proskauer, spoke on 20th September on a panel at the International Bar Association’s annual conference in Washington, D.C. The panel was entitled “Practical Issues in Entity Classification and Claiming Tax Treaty Benefits for Transparent Entities”.

Along with co-panelists from the U.S., Argentina, Spain, Canada and the Netherlands, Robert looked at:

  • Mismatches of treatment between those countries in how partnerships are treated for tax purposes
  • Issues created by the current OECD BEPS project in relation to the ability of taxpayers to claim double tax treaty benefits through partnerships, LLCs and other transparent and hybrid structures
  • The continuing implications of the UK Supreme Court judgment in Anson v. Commissioners for Her Majesty’s Revenue and Customs
  • The EU Anti-Tax Avoidance Directive and its effect on hybrid entities

Materials from the presentation are available to IBA members on their website.