MILAN 20-21 MAY 2021 – HOTEL PRINCIPE DI SAVOIA
MOBILITY OF IPS AND SERVICES– CORPORATE TAX ASPECTS
Chair: Robert Danon
- IP Box
- Characterization of income
- Withholding tax aspects
The Break-out Session III shall discuss issues of implementation of IP Box regimes and the way these regimes have evolved and might be further evolve in the light of the balance between residence and source taxation. The session shall also include a debate on income tax issues which may arise from the following: (i) mobility of business functions within groups; (ii) services (iii) characterization transactions related to IP (e.g. sale of IP vs license of IP) and (iv) income streams under treaties (Article 12 vs Article 7 OECD Model Convention). Similar issues of characterization regard cloud computing or streaming.