Beneficial Ownership

Tanggal
22 Januari 2013

Tempat
Menara Satu Sentra Kelapa Gading
6th Floor, Unit #0601
Jl. Boulevard Kelapa Gading LA3 No.1
Summarecon, Kelapa Gading
Jakarta Utara 14240

Pukul
09.00-17.00 WIB

Pendahuluan
The concept of “Beneficial Ownership” plays an important role in determining whether, pursuant to a particular tax treaty, a taxpayer is eligible for a lower rate of withholding tax on dividends, interest and royalties received by the taxpayer. Many tax authorities throughout the world are being vigilant in determining whether a recipient is the “Beneficial Ownership”. Further, more than 30 years after it was introduced in the OECD Model, and despite the scholarly attention, the meaning of beneficial ownership still remain UNCLEAR. Yet, the appropriate meaning to be given to this term (beneficial owner) still remain one of the most DEBATED questions of international tax law. Recently, decided cases from all over the world and the publication of an OECD Discussion Draft on the Meaning of Beneficial Owner were able to trigger a new wave of scientific activity in this field.

Therefore, tax practitioners, as well as tax manager of multinational corporations, were truly interested to learn more on the concept of “Beneficial Ownership” and interested in obtaining a more precise overview on how courts and administrative authorities applied the concept of “Beneficial Ownership” would take a benefit by being a participant of this seminar. This seminar will discuss the development of “Beneficial Ownership” concept, interpretation (broad and narrow) of “Beneficial Ownership”, courts and administrative view in various cases from Indonesia and foreign country, and an overview of OECD Discussion Draft on the Meaning of Beneficial Owner.

Speakers:

Darussalam, Managing Director of DANNY DARUSSALAM Tax Center
Yusuf W. Ngantung, Manager of International Tax Advisory and Corporate Restructuring Services at DANNY DARUSSALAM Tax Center

Facilities:
Seminar kit, Updated hardcopy material, Certificates, Coffee break and meals, Library access, and others modern supporting facility

Investment:
IDR 2.500.000 per person. Due to limited seating available (25 seats), we recommend that you register early to reserve your seat