Anti-Tax Avoidance Directive 1

Course Outline:

Following the publication of the Base Erosion and Profit Shifting (BEPS) final reports in October 2015, a decision was taken at European Union (EU) level to introduce the Anti-Tax Avoidance Directive (ATAD EU 2016/1164) as part of a package of measures aimed at ensuring a common and coordinated approach across EU Member States to the introduction of BEPS anti-avoidance measures. The first ATAD, presented in January 2016 and agreed by all EU Member States in July 2016 provided for five separate anti-avoidance measures to be implemented on an agreed schedule between 2018 and 2023.

Consequently, Legal Notice 411 of 2018 published on 11th December 2018 implemented ATAD in Maltese law. The Maltese implementation of ATAD (which can be found here) includes four articles: interest limitation rule, exit taxation, general anti-abuse rule (GAAR) and controlled foreign company (CFC) rules. These articles (with the exception of exit taxation which will come into force on 1st January 2020) came into force from 1st January 2019. In addition, these articles, with the exception of GAAR, are broadly novelties for Maltese law. The purpose of the workshops is to analyse these articles, discuss their potential effects in Malta and consider practical interpretation issues.

There will be two workshops: one introducing ATAD 1 and covering the interest limitation rule and GAAR and the second covering CFC rules and exit taxation.

This is a link to our factsheet on the Maltese implementation of ATAD 1.

Target Audience:

Tax professionals (including accountants, auditors, in-house professionals).

Trainers:

Roderick Borg – Associate Director, International Tax Advisory, KPMG Malta

Roderick is an accountant by profession, joined the tax function of KPMG after graduating with a first class degree in both the B. Com course and the B. Accty (Hons.) course from the University of Malta. In 2010, Roderick was awarded the diploma in taxation with distinction from the Malta Institute of Taxation. Roderick is currently an Associate Director involved in the provision of direct and indirect tax compliance and advisory services to domestic and international corporate and individual clients. He also delivers lectures in various seminars and professional educational activities relating to taxation matters including taxation modules to students reading for their ACCA qualification.

Michail Tegos – Associate Director, International Tax Advisory, KPMG Malta

Michail, a lawyer, read his master’s in tax law at the International Tax Center, University of Leiden, the Netherlands. Following graduation from his master’s degree, he was handpicked and asked to stay on as the academic coordinator for the next two-and-a-half years, and he still lectures on the taxation of shipping and air transport. He is an associate director at KPMG Malta involved in the provision of tax advice to a broad range of international businesses, including a number of multinationals, in respect of a diverse range of projects including tax structuring, group restructuring and financing, and in the provision of advice on international tax issues as regards investments made into, out of or through Malta.

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Terms and conditions.

Course Features

Guided Learning 7 hours
Language English
Assessments

Roderick Borg

Director

Roderick Borg is an accountant by profession. He joined the tax function of KPMG after graduating with a first class degree in both the B. Com course and the B. Accty (Hons.) course from the University of Malta. In 2010, Mr Borg was awarded the diploma in taxation with distinction from the Malta Institute of Taxation. He is currently a Director involved in the provision of direct and indirect tax compliance and advisory services to domestic and international corporate and individual clients. He also delivers lectures in various seminars and professional educational activities relating to taxation matters including taxation modules to students reading for their ACCA qualification.

Michail Tegos

Associate Director

Michail Tegos, a lawyer, read his master’s in tax law at the International Tax Center, University of Leiden, the Netherlands. Following graduation from his master’s degree, he was handpicked and asked to stay on as the academic coordinator for the next two-and-a-half years. He is an associate director at KPMG Malta involved in the provision of tax advice to a broad range of international businesses, including a number of multinationals, in respect of a diverse range of projects including tax structuring, group restructuring and financing, and in the provision of advice on international tax issues as regards investments made into, out of or through Malta.