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Foundation and ideals

ITCA was conceived by the 2015-2016 ITC Class during the summer of 2016 in Leiden, The Netherlands. Its first and current Board of Directors is constituted by Alberto Romero as President, Lydia Ogazón as Secretary and Oleksii Sydoryn as Treasurer, while Shyam Sundar Manivannan leads our Supervisory Board. Our original objective was and still is the creation of an extensive network of ITC alumni, while at the same time allowing anyone in the world to access our Directory and browse through the profiles of our members.

Mission

ITCA seeks to be a network of dynamic, lively, international and talented professionals with a specialized educational background and solid experience in International Taxation. The LL.M. degree obtained from ITC Leiden and the University of Leiden assures that our members are part of a selected group of the world’s top experts in the field International Tax Law. With such guarantee, our mission is to address the ever-developing tax issues of the modernized world and offer valuable feedback and insights into those issues.

New tax world

Globalization, along with the disruptive nature of the digital economy, has caused business models to evolve, rendered tax planning and tax compliance more complex, and created a growing need to align taxation with a complex new world. In this context, our objective is to provide up-to-date, solid and accurate insights and solutions for the tax issues of a fast-paced, globalized world.

Our areas of expertise

Cross-border taxation

Doing business across borders requires a clear understanding of cross-border taxation. Tax issues become more complex, especially nowadays that cross-border transactions are increasingly under the spotlight. Profits must be taxed where economic activities occur and where value is created. Businesses and individuals investing abroad face unfamiliar tax laws and different regulatory environments. Withholding tax obligations, CbC reporting requirements, tax treaty provisions, transfer pricing regulations, CFC regimes and anti-tax havens provisions, are only some of the issues that deserve special consideration. Therefore, an early analysis of cross-border transactions and their tax consequences will definitely help to accurately comply with multijurisdictional tax obligations and reporting requirements, optimizing results and minimizing risks and adverse consequences.

– Lydia Ogazón

Tax optimization

Multinationals nowadays are in constant competition to provide their customers the best products and services for the lowest prices. In this regard, tax optimization is a key driver and a competitive advantage to reach the efficiency which competitive markets require. Tax optimization involves planning to achieve paying the right amount of taxes in every jurisdiction involved, reducing financial and operational costs in a manner which meets legal requirements. It involves deep analysis of the multinationals’ tax attributes, assets, liabilities and financing possibilities and the correct interpretation and application of domestic law and tax treaties of all the jurisdictions in which the taxpayer operates.”

– Eduardo Orellana

Tax treaties

Tax treaties coordinate different tax systems around the globe, promoting cross-border trade in goods and services, as well as the movement of capital, technology, and persons, by removing or reducing double taxation. Additionally, these international agreements also aim to combat tax avoidance and fiscal evasion. One can say that tax treaties represent the agreement between States of what is a ‘fair allocation of taxing rights’. As it has a direct impact on the tax liability of any cross-border transaction, tax treaty interpretation and application is a very complex area increasingly dominating the majority of international tax discussions.

– Juan de la Cruz Higuera

Transfer pricing

Transfer pricing is the area of tax law and economics that deals with the price setting of transactions between related parties (typically, constituent entities of multi-national enterprises),  for the transfer or provision of goods, services and intangibles in accordance with the arm’s length principle. Under this principle the members of a multinational group must be treated as separate entities rather than as inseparable parts of a single business and would need to transact at prices as would be agreed between independent parties.

– Fabián Andrés Acosta

European Tax Law

European Tax Law is an increasingly relevant field of international taxation dealing with the interaction between the national fiscal sovereignty of the EU Member States in adopting direct tax measures and the limitations imposed to it by the jurisprudence of the Court of Justice of the European Union as well as the secondary law instruments applicable within the Union. The reach of European Tax Law has displayed unprecedented growth in the last couple of years to also extend to fiscal State aid, whose impact has been felt on both sides of the Atlantic as evidenced by the highly disputed Apple case. Taxpayers, whether they are situated in the EU or doing business with the EU, need to take these developments into account.

– Erisa Nuku

Exchange of information (EoI)

In what regards EoI, one has to admit that the last decade has been a turning point. In a short time span, practitioners have witnessed the shift from the old standard, based on bilateral relations and exchanges upon request, to a new standard where multilateral automatic EoI has become the norm. In this context, approaches such as FATCA and CRS are giving – or will soon give – countries access to information they never had before, while Country by Country Reporting and the Compulsory Spontaneous EoI in Respect of Rulings allow for an unparalleled understanding of Multinational Entities’ revenue allocation, and the reasons behind it. These significant changes bring forth many challenges must be dealt with by taxpayers, tax advisors and tax authorities alike.

– Caio Casiraghi

Advanced pricing arrangements (APAs)

Advanced pricing arrangements (APAs) determine, prior to controlled transactions, an appropriate set of criteria (e.g. method, comparables and appropriate adjustments thereto, critical assumptions as to future events) for the determination of the transfer pricing for such transactions over a fixed period of time. An advance pricing arrangement may be unilateral involving one tax administration and a taxpayer or multilateral involving the agreement of two or more tax administrations. APAs have emerged as a very effective tool for MNEs to ensure tax certainty and avoid transfer pricing disputes by agreeing on pricing with the tax authorities beforehand.

– Fabián Andrés Acosta

Transaction taxes

In a globalised world, transactions (especially cross-border transactions) such as acquisitions, disposals, refinancing, restructurings or initial public offers cannot be consummated without considering tax implications. Having a good understanding of your organisation and implementing a strategy by addressing tax issues early in the process are vital for mitigating the tax implications in order to enhance opportunities within the deal and provide key negotiation insights. With the increasing number of laws regulating this market, it is crucial, when in the process of executing these transactions, to keep an eye for alternative transactions where the tax priorities at the same time are balanced with your overall business objectives.

– Gaethan Bonte

Indirect taxes

Indirect taxation represents an efficient and significant source of revenue for most jurisdictions in the world. There has been a worldwide shift from direct to indirect taxes, especially those similar to VAT in Europe. Value added taxes have gained importance due to their appealing features, like stability, neutrality in trade, easier collection, and homogeneous tax treatment to goods and services. Nowadays, the digital economy embodies an important challenge for tax authorities that can affect their revenue sources regarding indirect taxation. Hence, the sphere of indirect taxes is witnessing a multitude of changes being introduced by jurisdictions which requires intricate advice for taxpayers to be able to comply while still optimizing their tax burdens.

– Juan de la Cruz Higuera

Investment structuring

Investing into new markets always represents challenges and risks for which careful analysis is required. Investment structuring must first begin with analyzing the local conditions and tax regime of a potential target jurisdiction. Once the selection of a jurisdiction is made, the correct investment vehicles, debt & equity combination and targets to be acquired, if applicable, need to be determined, to maximize tax benefits while simultaneously complying with anti-avoidance and anti BEPS local measures. The delineation and documentation of functions, assets and risks involved in each entity of the structure is required from the beginning. A complete investment structure analysis and implementation must always consider the most efficient tax strategy.

– Eduardo Orellana

Tax dispute resolution

Taxpayers are facing the most challenging tax environment in history. Currently, as a result of the recent efforts made by the international community to avoid base erosion and profit shifting in cross border and domestic scenarios, there is a substantial increase in the number and size of tax disputes between taxpayers and tax authorities worldwide. Dispute avoidance and resolution frames each phase of the controversy, starting from the pre-audit and audit stages, to going to court or entering into arbitration. Dispute avoidance and resolution procedures and tools if properly designed and implemented, enable fair and expeditious resolution of differences between administrators and taxpayers.

– Fabián Andrés Acosta

Regional representatives

Alberto Romero

North America

Lilia Isabel Lee

Central America and Caribbean

Fabián Acosta

South America

Lydia Ogazón

Europe

Paul Simanjuntak

Asia

Oleksii Sydoryn

Middle East

Hiroyuki Kimura

East Asia

Mariela Pacheco

Oceania