Tax counsel Marek Herm was one of the panellists at 2009 IFA Congress in Vancouver
The International Fiscal Association (IFA, www.ifa.nl) is the only non-governmental and non-sectoral international organization dealing with fiscal matters. It comprises taxpayers, their advisers, government officials, members of the judiciary and university professors and is therefore a unique forum for discussing international fiscal questions.
The annual IFA Congress is considered the most important IFA event of the year. The 63rd IFA Congress (www.ifa2009vancouver.ca) took place in Vancouver, Canada from August 30 through September 4, 2009. Its scientific programme was designed to be of keen interest to tax practitioners, in-house tax advisors, academics and government officials.
Marek Herm, tax counsel at Raidla Lejins & Norcous, was one of the panellists at a congress seminar ‘The death of withholding taxes?’. The seminar was chaired by Prof. Michael Lang, Head of the Institute for Austrian and International Tax Law at the University of Vienna.
This seminar examined the purpose and the nature of withholding taxes in general and discussed the typical areas where such taxes are applied, namely, taxation of dividends, interest, and royalties and income of artistes and athletes. It further, analysed the function and the admissibility of withholding taxation in intra-EU situations, paying particular attention to the ECJ case law and the relevant secondary Community law, such as the Parent-Subsidiary directive (90/435/EEC), the Interest and Royalties directive (2003/49/EC), and the Savings directive (2003/48/EC). For the discussion of withholding taxation in relation to non-EU-countries, (i) the free movement of capital, (ii) some specific agreements between the EU and some third countries, and (iii) the non-discrimination clauses of tax treaties, were of particular interest.
The slides of the seminar can be seen HERE.
