We warmly invite to an International conference organized by IFA Poland and IFA Germany entitled "Practical aspects of the application of the double tax treaty between Germany and Poland", which will take place in Kraków, Poland on September 25, 2023. The event will be held in English.
• Prof. Dr. Christian Kaeser, President of the Board at IFA Germany, Head of Tax at Siemens AG
• Prof. Dr. Xaver Ditz , Partner at FGS
• Berthold Welling, Secretary General at IFA Germany, Executive Manger at VCI (Association of Chemical Industry)
• Dr. Monika Wünnemann , Head of Tax at BDI (German Federation of Industries)
• Dr. Wojciech Sztuba, President of the Board at IFA Poland, Managing Partner at TPA Poland
• Prof. Dr. hab. Krzysztof Lasiński Sulecki , Board Member at IFA Poland, Director of the Centre of Fiscal Studies at Nicolaus Copernicus University
• Dr. Izabela Andrzejewska Czernek, Board Member at IFA Poland; Global YIN Committee Member, of counsel at Vinci & Vinci
24 September 2023
19:00 Opening lecture and dinner
25 September 2023
11:00-11:15 Introduction to the event
Prof. Dr. Christian Kaeser , President of the Board at IFA Germany
Dr. Wojciech Sztuba, President of the Board at IFA Poland
Part. I. The most and least contentious provisions of the DTT DE PL
The long history of mutual investment, the movement of capital and people, the creation of extensive supply and value chains, has provided a rich test base for each of the provisions of the bilateral DTT. Which have worked well and which have caused the most disputes or difficulties?
• Permanent establishment concept changing over time (profit allocation , highly integrated business structures , VAT fixed establishment, temporary construction PE, remote work & new technologies , outsourcing trends
• Transfer Pricing and the evolution of TP methods
• Relocation of manufacturing functions to low tax zones in PL
• Transparent entities LLPs , investment funds , trust contracts
• WHT / BO challanges and new duties
12:45-13:00 Coffee break
Part. II Polish German practice on dispute resolution and dispute avoidance
The large number of disputes concerning the application of the DTT between Germany and Poland makes it possible both to analyze the effectiveness of the available dispute resolution tools and to assess their actual impact on economic relations.
• Practical application of MAP ( mostly disputed topics
• Resolution practice in transfer pricing disputes
• Dispute resolution vs. avoidance
• Tax ruling / APA practice in both countries
• Administrative information exchange
Part. III. Impact of changes in the business and regulatory environment
15:30-17:00 Changing business models, remote working, ecommerce, the digitalization of economies, the electrification of the automotive industry and the decarbonization of industrial production. How will DTT PL DE deal with these and other challenges of the future? What changes to expected?
• Will both countries remain attractive investment sites for each other in a long run? What may change in the mutual lists of top investment advantages
• New definition of taxing rights as a result of Pillar One
• How mobility of work and automation may impact the future
17:00-17:15 Closing remarks
Prof. Dr. hab. Krzysztof Lasiński Sulecki , Board Member at IFA Poland
Prof. Dr. Christian Kaeser, President of the Board at IFA Germany
Registration and fees
EUR 150 / PLN 675 registration fee applies to IFA Members
EUR 200 / PLN 900 for other participants
The registration fee includes attendance to the conference sessions and official dinner on September 24 , 2023. It does not include accomodation and optional activities.