NAVIGATING THE POST-BEPS TAX LANDSCAPE

Join us for a high-impact webinar exploring the practical implications of the post-BEPS treaty environment, guided by Dr. Daniel N. Erasmus’s widely-read article, “Navigating the Post-BEPS Tax Landscape: Treaty Updates, Hybrid Mismatches, and the Rise of the Multilateral Instrument.” This session will provide a strategic briefing on critical developments arising from BEPS Actions 2, 6, 7, and 14, and their ongoing effect on international tax planning, treaty interpretation, and dispute resolution.

Key focus areas will include updated Permanent Establishment (PE) definitions under the MLI, including the tightening of rules surrounding commissionaire arrangements and the application of the anti-fragmentation rule. These updates have significantly expanded PE risk exposure, requiring multinationals to reassess longstanding structures.

The webinar will also delve into the denial of deductions under the EU Anti-Tax Avoidance Directive II (ATAD II) and the OECD’s hybrid mismatch rules under Action 2, offering insight into how jurisdictions are tackling double non-taxation outcomes through domestic legislation and treaty interplay.

Additionally, we will unpack the transformative impact of BEPS Action 6 on treaty abuse provisions and the use of the principal purpose test (PPT), as well as the practical rollout of mandatory binding arbitration under BEPS Action 14 and the MLI’s mutual agreement procedure (MAP) enhancements.

This session is designed for tax professionals, legal advisors, multinational tax teams, and policymakers who need to understand how the MLI and post-BEPS instruments are reshaping cross-border taxation. Dr. Erasmus will bridge theory and practice, sharing frontline insights and compliance strategies to help attendees future-proof their structures in an increasingly complex and coordinated global tax landscape. Don’t miss this opportunity to stay ahead of the curve.

What we will cover:

• BEPS Actions 2, 6, 7, 14
• Updated PE definitions and MAP arbitration provisions
• Commissionaire arrangements and anti-fragmentation under Article 5 MLI
• EU ATAD II and denial of deductions in hybrid mismatch scenarios

What You’ll Learn:

• How the OECD’s 2017 Model Convention update reshaped treaty interpretation
• Practical implications of the MLI, including Articles 5, 7, 29 and 25
• Why hybrid mismatch rules and transparent entities matter more than ever
• What the AOA says about profit attribution to PEs, and how case law like Zimmer, Roche, and Rolls Royce aligns
• Real-world examples of how the PPT, LOB clause, and holding period rules are being enforced globally

Look forward to seeing you on Monday 11th August for this exclusive online event!