The 71st Annual Congress of the International Fiscal Association (IFA) was held on 27 August – 1 September 2017, with 2,000 delegates from around the world gathering in Rio de Janeiro, Brazil, to discuss two main themes: the practical consequences of BEPS and the future of transfer pricing.

There was much discussion of the OECD’s new multilateral instrument, currently signed by 71 countries, which will update an existing network of approximately 1,100 bilateral tax treaties to implement the treaty-based recommendations of BEPS. These recommendations include measures to prevent treaty abuse, changes to the definition of permanent establishment, changes to residence tie-breakers, mutual agreement procedures, and mandatory binding arbitration. Consideration was also given to the tax transparency debate, including both intergovernmental exchange of information and public disclosure aspects.

Of particular relevance to ITIC were two seminars focusing on the resource industry:

Cost contribution arrangements, which are often used by multinational enterprises to recover research and other head office costs in a way that matches costs with benefits; and
An oil & gas tax seminar sponsored by PwC, covering tax transparency, offshore indirect transfers of interest and the latest developments in Brazilian oil & gas tax.

Exhibitors at the Annual Congress included PwC, the OECD, IBFD, the Advanced Diploma in International Taxation, Thomson Reuters, Wolters Kluwer, and the Qatar Investment Authority.

Working together with local partner GETAP and external experts, ITIC hopes to organize a workshop in Brasilia early next year to discuss local tax reform, dispute resolution and collaborative compliance.

Jim Robertson is an Advisor for the International Tax and Investment Center (ITIC), based in the U.K.