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New business substance requirements for global holding companies and treasury entities

February 12, 2019 @ 1:00 pm - 2:30 pm EST


Participants of the live webinar will be eligible for 1.5 free CPE credit.


As a direct consequence of the Organisation for Economic Co-operation and Development (OECD) base erosion and profit shifting (BEPS) recommendations, a new environment of business substance requirements is evolving for internationally operating holding companies and treasury and license entities.

To help such entities recognize and address these changes appropriately, our panel will review these new business substance requirements and related developments within and outside the European Union (EU).

The panelists will discuss the following topics:

  • New business substance requirements for entities established in jurisdictions listed in Annex II of the EU’s list of non-cooperative jurisdictions for tax purposes (the so-called “grey list”)
  • Business substance requirements under the Principal Purposes Test (PPT) of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), as applied within and outside of the EU member states
  • Business substance and certain new EU member states’ controlled foreign company (CFC) and withholding tax rules

During this live, interactive webcast, you will have the opportunity to ask questions through the website, and the panelists will answer as many of your questions as time permits.

This program will likely be of interest to vice presidents/directors of tax/international tax, directors of finance, CFOs, international tax managers and tax accountants looking for the latest practical information and structuring considerations to support their global business initiatives. We hope you will be able to join us.


  • Simone Admiraal, Dutch Tax Desk, International Tax Services, Ernst & Young LLP
  • Jose A. (Jano) Bustos, Spanish Tax Desk, International Tax Services, Ernst & Young LLP
  • La Tanya Edwards, Caribbean Tax Desk, International Tax Services, Ernst & Young LLP
  • Robert Moncrieff, Global Insurance ITS Leader, Financial Services, Ernst & Young LLP


  • Thomas A. Eckhardt, German Tax Desk, International Tax Services, Ernst & Young LLP


February 12, 2019
1:00 pm - 2:30 pm
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Specialized Knowledge