Joint event by the MIA, MIT & IFSP

Registration Time: 09:15
Sessions Time: 09:30 - 12:00  

Speakers: Dr Rachel Zarb Cousin Deloitte, Mr Christopher Bergedahl Deloitte

Panel Members: Dr. Robert Attard, EY Malta Representative, Mr. John Ellul Sullivan MIT & IFSP Representative, Mr. Mirko Rapa MIA Representative, Dr Rachel Zarb Cousin and Mr Christopher Bergedahl Deloitte Representatives

Moderator: Mr Nick Captur, Deloitte

Venue:   Online Webinar

Participation Fees (The Institute is now accepting payments via Paypal)
MIA Members: €40.00 (Member's Rate applies only to those who already settled their 2022 Membership Subscription)

Non-MIA Members: €60.00

Retired Members: €40.00

Students: €15.00

As per terms & conditions, the Unlimited CPE Bundle cannot be used for this joint event.

background information

On 22 December 2021, the European Commission published proposals concerning shell companies and minimum substance requirements. The proposal as currently drafted is likely to have a material impact across the European Union, as well as on Malta’s corporate and financial services industry and, potentially, the broader economy. This session is intended to introduce participants to the policy objectives and structural mechanics of the directive, as well as to debate the general direction of travel of EU tax policy. If you are a director on, or an advisor to, a company that may be within scope of the directive, then knowledge of the potential implications of this draft directive is considered to be essential as 2022 is already within the proposed lookback period.

Specific topics to be covered during the session

• The political horizon: what are the prospects of the Directive becoming law, and when would it enter into force?

• Overview of the structure of the Directive

• The gateway criterion: what makes a company a reporting undertaking?

• The minimum substance criteria

• Tax effects of lacking minimum substance

• Disclosure requirements

• Expected interaction with Maltese law: case studies

• Moderated panel with a Q&A session

Target Audience

Tax practitioners, accountants, corporate service providers, trustees, advocates, law firms, executive and non-executive directors.

Speaker's Profile

Rachel Zarb Cousin is a Director within the Tax Business at Deloitte Malta and leads the International Tax service line. Rachel focuses on international tax consulting and advises both local and multinational clients operating in various industries including financial services and life sciences and health care. Rachel’s main focus is on group restructurings, inbound investment structuring and private equity investments. Rachel is the Grants and Incentives Leader at Deloitte in Malta, where her responsibilities include advising clients on grants and incentives available locally as well as EU funding. Following the completion of her postgraduate studies, she worked as a teaching assistant at the International Tax Centre in Leiden. Rachel has been admitted to the Maltese Bar and is a member of the Malta Institute of Taxation and a member of the Malta Institute of Financial Services Practitioners. Furthermore, Rachel is the Chairperson of the Education Committee of the Malta Institute of Taxation.

Christopher Bergedahl is a Senior Manager at Deloitte Malta within the International Tax service line, with a focus on the financial services sector. In 2017 he graduated summa cum laude from the International Tax Center Leiden following which he served as a Teaching Assistant for the Fall Term of the 2017-2018 class. Christopher is warranted to practice in front of the Superior Courts of Malta and is a member of the Malta Institute of Taxation, the Malta Branch of the International Fiscal Association and the Malta Institute of Financial Services Practitioners. Furthermore, Christopher is a member of the Education Committee of the Malta Institute of Taxation and actively contributes to technical working groups.

Mirko Rapa is a tax partner at PwC Malta and provides tax advice to a wide and varied portfolio of clients. Over the last 20 years has provided tax advice to companies operating in a number of sectors and individuals taking up residence in Malta.
Some of the assignments in which Mirko was involved included assisting a number of leading multinational groups with tax due diligence exercises and setting up their operations in Malta. Contributed to fiscal publications in respect of adequate substance requirements, transfer pricing, holding companies, fiscal implications of investing in Malta, exchange of information and setting up business in Malta.
Mirko also lectured in advanced taxation to students preparing for the ACCA and the Advanced Diploma in International Taxation (CIOT) examinations.

Nick Captur leads one of the firm’s international tax transaction services teams in Malta, focusing on transactions and implementation support, typically to US multinational groups. He also advises private business and their UHNWI owners under the Deloitte Private brand. His experience is mostly in Consumer Business, Technology and Life Sciences industries. He has over 16 years’ experience in this field and was previously a partner within Deloitte’s Financial Advisory practice and also worked in the UK and Australia. He currently serves on the Deloitte Private Global Executive and the Global Tax & Legal Talent Board and is a member of Deloitte’s Global Tax & Legal Learning Governance Group. He is also Vice President of the Institute of Financial Services Practitioners (IFSP) and a member of the Directors Working Group sub-committee of the IFSP.

John Ellul Sullivan is a Tax Partner at KPMG in Malta, having jointed in 2007, after graduating as a Doctor of Laws, and has completed an Advanced Masters in International Taxation at the International Tax Centre, University of Leiden. John is chair of the Malta Institute of Taxation’s Direct Tax Technical Committee and is a member of the Institute of Financial Services Practitioners Education Committee.

Robert Attard is Partner and Tax Policy Leader, EY, Central & South East Europe, a tenured senior lecturer at the University of Malta, a fellow of GREIT and member of the European Association of Tax Law Professors. In the IBFD’s 2015-2017 General Report on the Protection of Taxpayers’ Rights he was described as a well-known authority broadly experienced in the practical protection of taxpayers’ rights and a prominent member of the legal practice. Having served as a panellist at the 2015 IFA Congress he forms part of a study group of the International Law Association on the “Protection of Taxpayers’ Rights” (co-chaired by Advocate General Juliane Kokott and Pasquale Pistone) and is also a member of the Supervisory Council of the IBFD/IFA’s “Observatory on the Protection of Taxpayers’ Rights”. He has served as Visiting Professor at the University of Ferrara paying lecturing/speaking visits at Queen Mary (University of London), CTL (University of Cambridge), Salerno (with Wirtshaftsuniversitat Wien and Naples II) and the University of Palermo. The Maltese Court of Appeal has described him as a leading commentator on tax law referring to his publications in its judgements. Robert developed a detailed knowledge of tax aspects of the European Convention on Human Rights drafting submissions in cases filed against France, the Netherlands, Bulgaria and Malta. Robert is a published author on tax law publishing articles in European Taxation, EC Tax Review and the British Tax Review. He has contributed to several publications including a book published by Hart Publishing, 3 books published by the IBFD and several books published by the MIM. Philip Baker remarks that ‘Single-handedly, Robert is generating the literature which explains the structure and nuances of the system in Malta. One wishes other countries had similar authors who could write similarly enticing books to explain their tax codes.” Robert has argued most of Malta's leading tax cases including landmark judgments John Geranzi v. PM (right to justice within a reasonable time), Zahra v. PM (non bis in idem), Farrugia v. PM (taxation as a violation of the right to property) and Case 160 of 2012 (tax transparency).

EVENT CPE COMPETENCES

2.5 Hours  Core

WEBINARS TERMS AND CONDITIONS

Terms and conditions  apply

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