Registration Time: 13:15
Sessions Time: 13:30 - 16:45  including a 15-minute break
Speakers: Dr Christopher Bergedahl & Dr Ian Zahra
Venue:   Online Webinar

Participation Fees (The Institute is now accepting payments via Paypal)
MIA Members: €40.00
Non-MIA Members: €75.00
Retired Members: €20.00
Students: €30.00

*Group bookings for 3 or more participants available.

BACKGROUND INFORMATION

Malta transposed the Anti-Tax-Avoidance Directive (ATAD II) into its income-tax legislation on 24 December 2019. The directive tackles unintended tax advantages created by hybrid mismatch arrangements by layering a set of corrective rules that apply contemporaneously. During this session we will chart the most common hybrid-mismatch scenarios and explain, step by step, how each corrective mechanism works, while highlighting the practical effects these rules have on Maltese structures.

SPECIFIC TOPICS TO BE COVERED DURING THE SESSION

By the end of the workshop, participants should be able to identify transactions and structures that typically give rise to hybrid mismatches, apply the Maltese transposition of ATAD II to neutralise those mismatches, and assess the consequences of each rule on financing, group-relief claims and cross-border payments.

Why is the session of relevance to our members?

Mastering these provisions enables advisers to anticipate and eliminate costly hybrid-mismatch exposures, structure inbound and outbound flows with greater certainty, and guide clients when existing arrangements are caught by the rules.

Target Audience

The session is intended for tax advisers and in-house tax managers, corporate-services professionals involved in cross-border structuring, and anyone who needs a functional understanding of Malta’s anti-hybrid landscape.

Speakers' Profiles

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 the Chairperson of the International Tax Sub-Committee of the Malta Institute of Taxation and actively contributes to technical working groups.

Ian Zahra joined Deloitte Malta in 2020 and currently forms part of the international tax advisory team as a Senior Manager, focusing on domestic and international direct taxation. Ian has worked on a number of engagements dealing with the Malta direct tax consequences of local and foreign companies in various industries (namely, gaming, financial services and technology).
Ian is a lawyer by profession and, following his studies in law at the University of Malta, he graduated in international tax law from the University of Leiden in the Netherlands and received awards for the best paper of the 2018-2019 class which focused on the principal purposes test, entitled “The Principal Purpose Test: A critical analysis of its substantive and procedural aspects”. Following this experience, Ian also worked as a teaching assistant at the International Tax Centre in Leiden. Ian has been admitted to the Maltese bar.
Ian has been invited to deliver a number of seminars and lectures by various local bodies including the Malta Institute of Taxation, the Malta Institute of Accountants and Society Education Malta, covering various areas namely principles of international taxation and tax transparency. 

EVeNT CPE COMPETENCies

3  Core

WEBINARS TERMS AND CONDITIONS

Terms and conditions  apply

DISCLAIMER

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Please note that all webinars are recorded by the MIA. Such recordings will be retained by the MIA for internal use.