Russell Bedford’s International Tax Conference 2021

The first session of the day led by Jennifer D. Lindy, Esq. (Chamberlain, Hrdlicka, Attorneys-at-Law – Atlanta) was on Current IRS International Enforcement Campaigns and Remedies to Correct U.S. Tax Reporting. Jennifer discussed compliance considerations in respect of foreign trusts and challenges related to overseas investment into the US.

Hank Moonen (TaxModel – Netherlands) followed with a session on Tax Technology and the journey to Tax Advisory 2.0., discussing why tax technology is important, including internal and external drivers. Hank delivered a base understanding of the tax technology landscape and explained how to embed it into practice, while providing insight into the products that firms should be considering.

Day one closed with a panel discussion on Tax after Brexit – key changes in selected jurisdictions led by Stephan Strothenke (Halle in Westfalen), who was joined by panellists Francesco Cicculli (Rome), Jacobo García-Nieto (Barcelona), Gordon Hayden (Dublin) and Iain Lundie (Belfast).
 

A most interesting discussion, Gordon Hayden, while acknowledging the complexities faced by businesses, hailed this moment as an opportunity, saying: "With great change comes great opportunity; we’re being presented with a huge opportunity to sell our services to clients.

”He added: "UK businesses are aiming to use Ireland as a gateway into the EU and as a result we’ve been able to pick up several new clients to provide this type of support.

”Stephan Strothenke, adding to this point said: "It’s not enough to set up a company or a mailbox in an EU member state; what you need is substance, you need a presence in the country including employees based there.”

Iain Lundie touched on the complexities surrounding buying from the UK, now a ‘third country’, and the resulting issues with dispatching to Ireland. He said: "Dealing with VAT when selling into the UK, which pre-Brexit could be a 24-hour turn around, is now taking much longer and often comes with added challenges such as unfulfilled deliveries.

”Russell Bedford’s CEO, Stephen Hamlet, opened day two with a welcome and member update. Stephen talked about diversity within the network and the core values that hold everyone associated with Russell Bedford accountable for their words and actions when representing the network.

Talking about the incredible development the network has seen despite the challenges of the past year, he congratulated all those who have contributed to the impressive 13% membership growth; achieved not only through the addition of several new members, but by the net growth within existing members, who continue to expand despite such adversity.
 

Stephen welcomed new members since the previous year’s International Tax Conference and shared news of the recently completed IT upgrade project to enhance the global website, intranet and directory app; all part of the network’s growth strategy which is focused on attracting new member firms and enhancing the experience of existing members, globally.

Jeremy Mindell (Primondell) joined to share a synopsis of current international tax issues including BEPS 2.0, Transfer pricing changes, Tax changes and challenges in response to COVID, Changing US position on corporate taxes and International coordination on enforcement. Jeremy shared some excellent insights on the highly topical G7 tax changes following the agreement on 6 June 2021.

A panel session followed, which focused on an International Tax Case Study related to a UK-based online food delivery platform, setting up in North America and Europe and which needed advice on tax implications.

The discussion was led by Graham Caddock (London) who was joined by panellists Armando Aguila (Mexico City), Jaspal Dhillon (London), Steve Horn (Atlanta), Rocío Luna (Málaga) and Vanessa Richardson (The Hague).

A fascinating discussion resulted; on the complexities of current regulations that tend to suit corporations, but not so much the individual, thereby forcing sometimes difficult moral questions.

Vanessa Richardson shared a story of a case heard by the Amsterdam Court of Appeals in February 2021, where it was found that delivery riders are to be treated as employees. A key element of the decision was based upon the level of income of the riders, which stemmed around the inability to afford to protect themselves from, for example, disability and unemployment. It was therefore deemed that riders should be entitled to gain access to employment laws and social services.

When asked about CSR and the potential reputational risk for companies, with respect to looking after employees, Vanessa said: "People performing these types of delivery jobs are often students, they have no other income or protection. In The Hague, the general consensus is that these workers should be protected.

”Talking about alternative solutions, Jaspal Dhillon said: "There would need to be some sort of decoupling of the driver from the restaurant.

”This year’s conference closed with a fun Tax Trivia Quiz to help raise money for charity. After a tough few rounds, with some hard questions on bizarre tax rules throughout history, delegates had earned a disappointing amount as they reached the 16th and final question. However, choosing to gamble what they had earned for a chance to claim the maximum prize, with an overwhelming majority answering the final question correct, a grand total of £1,600 was raised for the winning charity. From a number of suggestions provided by delegates, the charity selected from an independent draw was ‘Save The Children’. An important reminder that children are the future!

Stephen concluded: "It’s fantastic to witness the energy of our meetings, which I continue to see online. Our members feed off each other’s energy and enthusiasm, and of course sharing varying insights and experiences is how they continue to learn and grow.”

He added: "The range of speakers and diversity of our sessions keeps our events interesting; and engagement is, as a result, very high. I feel that members take a lot from our expert speakers and our internal panel discussions showed the passion and indeed expertise of our people around the world. We are excited to look towards recommencing physical meetings as soon as possible; however, I can’t stress enough how much I have been impressed by our members, with their attitude and drive to continue to deliver their very best in this very different working environment.”