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YIN Seminar – Tax treatment of crypto assets

Moderator: Trevor Glavey (Ireland)

Despite the increasing prevalence of crypto assets many tax policymakers and administrations are still at an early stage when it comes to addressing their tax implications.

With crypto assets being a new phenomenon lawmakers can follow different approaches to the tax consequences across the various stages of their lifecycle.  New concepts like blockchain also need to be understood and added to our lexicon when considering the issues involved.  In addition, besides the mere trade in such assets many more activities such as mining and staking must be considered.

Join us at the YIN Seminar at the IFA Congress in Berlin on 7 September at 16.30 where we will explore some of the key concepts, discuss the tax challenges regarding the tax treatment of crypto assets and consider some of the developing responses from around the world with our panel of experts.

Opening Ceremony and Welcome Reception – Exhibition Hall

IFA Tax 2022 is officially kicking off! IFA President, Peter Barnes, has the pleasure to welcome you to the 74th Congress of the International Fiscal Association in Berlin.

The Opening Ceremony will feature the handing over of the Maurice Lauré Prize as well as the Mitchell B. Carroll Prize to the winners, a couple of interviews regarding IFA and this Congress plus interactive sessions to give us all the right spirit for a great and successful event. Stay tuned for some surprises, including a special guest.

Make sure you do not miss the chance to start your IFA Tax 2022 journey full of energy on Sunday, September 4, at 19:00 CET, in the Grand Ballroom of our venue (Hotel Berlin Central District).

The Opening Ceremony will be followed by a cocktail reception where you will be able to meet and exchange with your IFA friends and colleagues.

Proudly sponsored by:

YIN Party – Haubentaucher – 20:30 to 02:00

Shuttle transfer option from Hotel Berlin Central District: 19:30 and 20:45

Individual departures available

Life is better with a pool! Surrounded by the historic walls of the former RAW site, the area of the Haubentaucher extends over 4,500 square meters. The heart of the Haubentaucher is the 240sqm heated swimming pool, framed by a spacious sun deck made of white stone tiles and natural wooden floorboards. Sun beds, deck chairs and Mediterranean plants create a beach club atmosphere that is otherwise only found on the Mediterranean .

Have fun at a cool pool party enjoying the summer in the city.

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Gala Dinner – Konzerthaus Berlin – 19:00 to 22:30

Shuttle transfer option from Hotel Berlin Central District: 18:00 and 18:30

Transfer option from location to Hotel Berlin Central District: 22:30 and 23:00

Known as “Schauspielhaus” since the 19th century, the Konzerthaus is one of the three spectacular buildings on Gendarmenmarkt – the harmonious ensemble including the German and French Dome. The Konzerthaus is revered as a treasure of German neoclassical architecture. Celebrate with us a gala dinner in a very special and historical location.

Proudly sponsored by:

Museums Evening – Museums Island – 19:00 to 21:30

Shuttle transfer option from Hotel Berlin Central District: 18:30

Transfer option from location to Hotel Berlin Central District 21:30 and 22:00

Right in the heart of Berlin, nestled between the Spree River and the Spree Canal, lies the world-famous Museum Island. It is one of the most outstanding museum complexes in Europe . Five architects designed the impressive architectural ensemble in the heart of the city. Museum Island has been a UNESCO World Heritage Site since 1999.

Enjoy an exclusive visit of the museum after closing time together with a delicious dinner in an outstanding location – the courtyards of the museum.

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Event name: Art Tour

Price: 75 EUR P.P.

Description: On this 3h Art Tour, you’ll discover works of art across many mediums in the city’s most unique, interesting, cutting-edge galleries. Mitte is known as the artistic district and has developed into a hub for art, fashion and design. You’ll get to meet artists and curators who will fill you in on why artists are drawn to Berlin like moths to a flame. The Art Tour has been carefully edited with the stylish visitor in mind, who will have an opportunity to discover, experience or buy new art and cool fashion, learn about trends and find out about emerging creative talent.

Max. Pax: Bookable up to 30 PAX

Min. Pax: Min. number of attendees: 15 PAX

Starting Point: Tucholsky Straße 12, 10117 Berlin

Ending Point: Hotel Berlin Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Event name: Sustainable Bike Tour

Price: 95 EUR P.P.

Description: Let yourself be inspired by innovative urban planning concepts, urban farms, ethical stores, backyard workshops, circle economy businesses, technology-driven start-ups and exciting community projects. The best and most environmentally friendly way to see the city is by leaving taxis and public transport behind, and exploring Berlin’s cultural sites and abundant green areas by foot and bicycle. Discover the coolest eco-minded places and projects of Berlin during a 4h Biking Tour incl. English speaking guide.

Max. Pax: Bookable up to 30 PAX

Min. Pax: Min. number of attendees: 10 PAX

Starting Point: Anhalter Strasse 11, 10963 Berlin

Ending Point: Anhalter Strasse 11, 10963 Berlin

Cultural Evening – Berlin Dom – 19:00 to 20:00

Shuttle transfer option from Hotel Berlin Central District: 18:00 and 18:40

Transfer option from location to Hotel Berlin Central District: 20:00 and 20:40

The sublime Berlin Cathedral in the heart of the city cannot be overlooked thanks to its striking dome. A visit to the cathedral is not only a must for every church lover, as it is richly decorated on the outside and inside – after climbing up to the dome, visitors are offered an exciting view over Berlin’s city center with the Spree River, the Lustgarten and Museum Island.

Enjoy this heavenly place with a concert of a traditional choir.

Proudly sponsored by:

Event name: IFA President’s Golf Cup

Description: Golf Tournament hosted by Peter Barnes and Jeanne Goulet. Join this spectacular first time IFA Experience at the wonderful Golf Yard at Schloss Wilkendorf on a first come first serve basis. Organized as a full service event including transfer service.

Max. Pax: 50 Pax

Meeting point for the shuttle service: 08:30 – Hotel Berlin Central Destrict / Lobby entrance area

Departure: 08:50, arrival 10:30

Return: 19:30, arrival 21:10, Hotel Central Destrict Stauffenbergstraße 26, 10785 Berlin

WIN Event: Bytes of Berlin – Boat trip

On Wednesday, WIN activities will close with a social event to facilitate global networking. We would like to invite you to join the WIN event on the Spree. On the solar-powered boat “Hermine” we will enjoy the beautiful scenery of Berlin-Mitte. After an inspiring and future-oriented discussion of our top-class and expert guests on the topic of “Digitalisation – A.I. in practice”, we are looking forward to a lively social exchange.

The boat will depart near the German Reichstag building on Wednesday afternoon at 5:30pm (boarding time 5:00pm) and will also dock there again at approximately 7:30pm. A shuttle from the congress hotel is organized to bring you on board in time (departure time at the hotel 4:30pm) and will bring you back to the hotel afterwards if you wish.

Bytes of Berlin is an exclusive event for a limited number of participants. So do not miss to register on the WIN Germany website, where you can also find more information.

Chair: Porus Kaka (India)

The IFA/OECD Seminar addresses the major developments in the International Tax arena. There will be an update from Mr Pascal Saint-Amans, Director of the Centre for Tax Policy and Administration at the OECD and Mr Achim Pross, Head of the International Co-operation and Tax Administration Division at the OECD, of the work that is currently underway at the OECD. The Panel will focus on the current Pillar One and Pillar Two proposals, their status, implementation and timelines, policy considerations and critical analysis.

The Panel will consist of two segments which will examine Pillar One and Pillar Two, with panelists from major Government representatives, academics and corporate representatives.

Chair: Georg Kofler (Austria)

The IFA/EU Seminar will offer a comprehensive overview and analysis of the most important (mainly direct) tax and tax policy developments concerning the European Union in the past year. The seminar will start with a presentation of the recent and ongoing tax policy projects undertaken by the European Commission (DG Taxation and Customs), including the EU’s work on the implementation of Pillar Two and numerous other initiatives in the area of direct taxation (e.g., “Unshell”, DEBRA etc).

After setting the stage, the seminar will focus on four particular areas: First, we will analyse the global corporate tax reform (Pillar Two, DEBRA) in light of EU law, including particular challenges of implementation as well as overarching topics of EU law, such as internal and external competence. Second, we will focus on the future of anti-tax avoidance and “aggressive tax planning” from an EU law perspective. This focus will not only address recent proposals, such as “Unshell” (and its potential extension to third countries), but also the impact of the ”Danish cases” on the interpretation of GAARs and the indirect effect on the “Whistleblower Directive”. Moreover, we will address developments in the Code of Conduct and highlight developments in European case law, such as the impact of the fundamental freedoms on interest barrier rules (Case C-3/21, PRA Group Europe). Third, we will highlight advances in administrative cooperation and compliance, including DAC7, joint audits and public CbCR, as well as the taxpayers’ position and rights in these areas (e.g., regarding professional privilege, penalties, and proportionality). Fourth, and finally, we will briefly examine recent progress in the area of energy and green taxation, which has become a new focus area with entirely new challenges in light of the renewed discussion about the energy transition and diversification following the Russian war in Ukraine.

Fun Run

We invite you to join participants of the IFA Congress for a joint run on 6 September at 7 a.m.

Get a healthy start into the day and enjoy a beautiful run through Berlin’s Tiergarten – a piece of nature in the middle of the city. Register now and get your runner’s package including healthy snacks at the Flick Gocke Schaumburg exhibition stand.

Proudly sponsored by:

President’s reception

Venue: Hotel Berlin Central District

The reception hosted by the President of IFA will be held at the Congress Venue on Wednesday afternoon, starting at 17:00. All participants are invited to this event which includes the Boards of the IFA Branches.

WIN Luncheon – Hotel Berlin Central Destrict

We invite female participants to join the WIN Luncheon on Tuesday. During the Luncheon, WIN branch representatives report on the WIN activities held in their branch during the year and what types of issues and problems arise in different countries. We have the opportunity to learn and support each other!

WIN Seminar – Tax challenges of matrix organizations, new work and the war for talent

This seminar, organized by the Women in IFA Network, will address the tax challenges of matrix organizations, new work and the “war for talent”. For example, managers of corporate functions are now often not located where the employees of the relevant departments are based, or central functions are often no longer performed at the location of the group parent company, but in another group company at a different location. As a result, group tax departments have to deal with the question of the possible establishment of a permanent establishment with a wide range of follow-up questions, in particular with regard to structuring options, questions of profit allocation and with regard to the fulfilment of the corresponding compliance obligations. The administrative burden for the companies, but also for the tax administration, is often high, sometimes out of proportion to the financial impact.

The WIN seminar focuses on these challenges and discusses the different perspectives of several countries. In addition to practical considerations on how to avoid micro permanent establishments in such cases, the seminar will address the legal solutions currently under discussion.

WIN Reception – Hotel Berlin Central Destrict

WIN Germany welcomes you at its reception hosted by Dr. Gabriele Rautenstrauch, Chair of WIN Germany, at the WIN Lounge in the Hotel Berlin Central Destrict (Win Lounge) between 4pm-6pm. Start your congress experience with this networking event.

Open for all female participants of the congress. No registration is needed.

President’s Reception

Venue: Hotel Berlin Central District

The reception hosted by the President of IFA will be held at the Congress Venue on Wednesday afternoon, starting at 17:00. All participants are invited to this event which includes the Boards of the IFA Branches.

More information coming soon.

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More information coming soon.

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More information coming soon

Event name: Sailing Tour

Price: 250 EUR P.P.

Description: You want to spend a relaxing time on the water, enjoy nature and gain insights into the nautical craft at the same time? Then let’s go sailing at the Lake Templin in Potsdam. The skipper is of course with you the whole time and it is up to you whether you simply enjoy the wind and the beautiful nature or actively lend a hand. Feel the wind, the waves and experience unforgettable moments with lots of fun and good humor.

Incl. bus transfer to Lake Templin Potsdam, sailing equipment and skipper.

Max. Pax: Bookable up to 50 PAX

Min. Pax: Min. number of attendees: 15 PAX

Starting Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Ending Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Event name: Delicato Tour

Price: 160 EUR P.P.

Description: Your guide will showcase Berlin’s most eclectic
pantries, creative snack bars, gourmet stores, a traditional coffee roastery, tempting confectionery, street food eateries, and much more. You will get to experience Berlin through your senses – as you taste, touch, smell, see and hear all about the city’s fascinating food culture. You’ll also discover Berlin’s dynamic world beyond the touristic mainstream, the hidden oases, the historic sites, the cool neighbourhoods, and the creative architecture.

Bus transfer (20 min.) to the starting point included.

Max. Pax: Bookable up to 30 PAX

Min. Pax: Min. number of attendees: 15 PAX

Starting Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Ending Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Event name: Urban City Tour

Description: This 3h tour is perfect for those who want to see it all: the traditional attractions and the edgy highlights of Berlin as a living and breathing city. Your personal guide presents Berlin’s history and also explains
how the city’s development is taking shape. You’ll discover Berlin’s dynamic world beyond the touristic mainstream, the hidden oases, the historic sites, the cool neighbourhoods, and the creative scene. You’ll experience Old Berlin and New Berlin as your guide reveals stories about Berlin’s vibrant nightlife, trends, cultural life, scandals, the creativity and subcultures that influence the city.

Max. Pax: Bookable up to 900 PAX

Min. Pax: Min. number of attendees: 50 PAX

Starting Point: Berlin Mitte (tba detailed location)

Ending Point: Berlin Mitte (tba detailed location)

Event name: Trabi Safari

Price: 155 EUR P.P.

Description: Enjoy the “speed” of 30 km/h and the tricky gear stick on the route through the streets of Berlin in a Trabi. On a tour with our old but ordinary fleet, driving fun is guaranteed. Your guide will provide you with information about historical facts and funny things via radio (walkie-talkies).

National driving license of your country is fine. Please note it has to be a driving license for cars with manual transmission. For drivers of automatic gearbox E-TRABIs are available in limited numbers. Bus transfer to the meeting point (6 minutes) included.

Max. Pax: Bookable up to 30 PAX

Min. Pax: Min. number of attendees: 10 PAX

Starting Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Ending Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Event name: Photoshoot

Price: 150 EUR P.P.

Description: Slip into vintage clothes, jump into a scenery and get to know yourself in a new light. Enjoy a great photoshoot and create unique souvenir photos.

Bus transfer, all pictures digitally and 1 A4 paperprint, snacks and drinks are included.

Max. Pax: Bookable up to 30 PAX

Min. Pax: Min. number of attendees: 15 PAX

Starting Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Ending Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Event name: KPM Masterclass

Price: 150 EUR P.P.

Description: A visit to the KPM exhibition provides exclusive insights into the artistic and craftsmanship of the 250-year-old luxury manufactory. Following the one-hour museum tour, you will learn everything about the production of porcelain in a workshop and make your own piece.

Bus transfer to the manufactory included. Shipping costs for the self-made porcelain as an extra charge depending on shipping country.

Max. Pax: Bookable up to 16 PAX

Min. Pax: Min. number of attendees: 10 PAX

Starting Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Ending Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Event name: Boat Tour MS Marpel

Price: 110 EUR P.P.

Description: Experience the highlights of the city from the water in the ambience of the cult ship MS Marple. During your 3h boat tour along the Museum Island, the Reichstag and the government district, your physical well-being is taken care of.

Bus transfer to the starting point included.

Max. Pax: Bookable up to 27 PAX

Min. Pax: Min. number of attendees: 27 PAX

Starting Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Ending Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Event name: Guided Shopping Tour

Price: 70 EUR P.P.

Description: The tour gives gives you not only the opportunity to discover and buy cutting-edge fashion, but to be briefed on the latest trends and discover emerging break-through Berlin designers and labels.

You will enjoy boutiques, department stores and shopping malls. There is also a focus on showcasing the most cutting-edge stores in the city from up-and-comers to internationally renowned names, as well as the best in furniture and home accessories, gourmet delicatessens and a selection of trendy galleries.

Max. Pax: Bookable up to 30 PAX

Min. Pax: Min. number of attendees: 15 PAX

Starting Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Ending Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Event name: Golf Lesson

Price: 500 EUR P.P.

Description: Take the opportunity and complete an intensive course to achieve the license to play golf within your stay in Berlin. The 3h lessons each day take place on one of the most beautiful golf courses in Berlin – Gross Kienitz. Equipment and catering provided. Bus shuttle is included.

Max. Pax: Bookable up to 50 PAX

Min. Pax: Min. number of attendees: 20 PAX

Starting Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Ending Point: Hotel Central Destrict
Stauffenbergstraße 26, 10785 Berlin

Event name: Create your own fragrance 

Price: 250 EUR P.P.

Description: Enter into a dialogue with fragrances and combine them at your personal discretion to create a new and unique creation. Fragrance experts will assist you with their knowledge and experience. The highlight of the course is the composition of an individual perfume for each participant. All participants will receive their individual perfume (50 ml) in an elegant bottle.

A glass of sparkling cava, chocolate covered macadamia nuts from Maison Macolat and gourmet popcorn from Knalle Popcorn will compliment your fragrance experience.

Max. Pax: Bookable up to 20.

Min. Pax: Min. number of attendees: 10 PAX

Starting Point: Frau Tonis Parfum Berlin – Manufaktur Zimmerstraße 13 (Checkpoint Charlie) | 10969 Berlin

Ending Point: Frau Tonis Parfum Berlin – Manufaktur Zimmerstraße 13 (Checkpoint Charlie) | 10969 Berlin

Chair: Jonathan Schwarz (United Kingdom)

This permanent seminar at all IFA Congresses, brings the latest and most important issues that impact international taxation around the world. The main focus of this seminar will be on recent judicial decisions on key international tax topics such as tax treaties, transfer pricing and domestic tax rules with cross-border implications. The final agenda for the seminar is normally decided close to the Congress date to make sure that it is as current as possible.

Chair: Stéphanie Auféril (France)

This session will focus on the relocation of the high-net worth individuals as a global trend of mobility of the families, and the competition between countries to attract the wealthy, notably with special tax regimes. We will discuss the tips and pitfalls of a multi-jurisdictional relocation planning, including the pre-immigration strategies, access to treaty network, in particular when attractive tax regimes are at stake, for both income tax and estate taxes, exit taxes… The debates will be illustrated with the input of experts from European countries (Italy, Portugal, United Kingdom), the United States and Israel.

Chair: Miranda Stewart (Australia)

This Seminar will focus on key challenges in international tax for developing countries, including base erosion and profit shifting (BEPS) and their experience in regard to the OECD-led BEPS reforms. Panellists from government, the private sector, business and academia will address topics including the effectiveness, or not, of tax transparency measures for developing countries; positive or negative impact of BEPS Actions especially concerning foreign investment, transfer pricing and enforcement; and Inclusive Framework Pillars 1 and 2. The panel will identify the successes and failures of BEPS reforms in responding to the needs of developing countries, including through case studies. It will explore alternatives and improvements, and debate how to achieve relevance and engagement for all countries of the new international tax regime.

General Reporter: Gary Sprague (USA)
Chair: Wolfgang Schön (Germany)

“Big Data”, i.e. projects, software, services or business functions that involve collecting, aggregating, structuring, and analysing large information sets, in particular the application of data analytics and artificial intelligence, has given rise to multiple business models permeating the global economy. The panel will provide an introduction to the main legal and fiscal features of Big Data and will discuss elected business models and their treatment under domestic tax law, tax treaties and the law governing indirect taxation (including VAT and DST). A central element of this analysis will be the interaction between the legal and fiscal characterisation of Big Data transactions.

Chair: Joachim Englisch (Germany)

This seminar will deal with practical aspects and challenges faced by businesses in ensuring VAT neutrality of their operations. A first point of discussion will be the complexities that often surround the claim of an input VAT deduction or credit. We will analyze both elements of substantive VAT legislation that can hinder or complicate an adequate relief from input VAT as well as procedural obstacles to this effect. In a second step, the real-world deviations from the principle of equality of competition that is inherent to VAT neutrality will be analyzed. In this context, particular attention will be given to the concepts of channel neutrality in a digitalized economy and the nascent trend towards “greening” the VAT system. We will furthermore explore how VAT compliance requirements may distort business decisions contrary to the neutrality principle, especially in a cross-border environment. All analysis will involve the discussion of possible solution to the aforementioned challenges, with a special focus on the role that new technologies could play in this regard.

Chair: Tatiana Falcão (Brazil)

The panel will discuss how the Paris Agreement goals, personified into the nationally determined contributions (NDCs) assumed by the countries member to the Agreement, can translate into fiscal and more particularly, tax obligations in a mid to long-term scenario. In doing so, the panel will discuss (i) what it means to price carbon, (ii) the constitutive elements of a carbon price (with an emphasis on taxation aspects), (iii) how Border Carbon Adjustment (BCAs) mechanisms relate to the domestic application of a carbon price, and finally, (iv) what types of plurilateral and multilateral approaches have been suggested to obtain a coordinated approach to the pricing of carbon.

Chair: Christian Dorenkamp (Germany)

Starting in Brazil several years ago, tax compliance processes all over the world are on an amazing journey of being end-to-end digitized. This does not only hold true for VAT purposes (with all invoices potentially being sent through a government agency, as in Italy), but also for corporate income tax assessments, for instance monthly balance sheet reporting obligations in Poland and both ICAP 2.0 and SAF-T model rules issued by the OECD. Recently, India went even one step further by introducing a completely virtual (“faceless”) tax audit process, waiving all personal interaction between taxpayer and tax authority whatsoever. In particular, the seminar will also look at what presumably lays ahead of us, for instance using artificial intelligence in tax audits and introducing common EU e-invoicing standards.

Chair: Wilhelm Haarmann (Germany)

The topic of this panel has to do with legal tax duties and moral tax duties, with legality and legitimacy and with reputation. Tax compliance is part of the corporate governance. To which extent is tax planning legal and legitimate, to which extent legal and illegitimate and when is it illegal? Are tax offerings by other countries acceptable and when inacceptable? Does public Country by Country reporting lead to a new moral standard? To which extent are general answers possible, to which extent do they depend on the habits, the expectations, and the general behaviour in a country or in a location?

Chair: Madeleine Simonek (Switzerland)

Dependencies of domestic taxation on foreign tax treatment is not a completely new phenomenon. Since the beginnings of international tax law, the credit method has taken foreign taxation into account to avoid double taxation. For more than 20 years, according to the OECD Commentary, qualification conflicts should be resolved by binding the residence state to the source state’s domestic understanding of a term. However, it is only recently that the linking of tax systems has taken on central importance in the context of the BEPS project, especially through the introduction of linking and subject to tax rules. The increasing intertwining of tax jurisdictions is a strong driver of complexity and requires constant consideration of foreign law. The aim of the seminar is to discuss these developments, their imitations as well as specific practical and legal problems raised by them.

General Reporters: Johanna Hey (Germany) and Arne Schnitger (Germany)
Chair: Janine Juggins (UK)

Most corporate taxation systems began life under a separate entity approach. Over time elements of a group approach have been layered on top. However, certain of the BEPS developments have further expanded the scope for groups to be treated differently in the context of cross border transactions. Pillars 1 and 2 go even further in some cases for larger groups by disconnecting the group treatment from the underlying transaction. Being part of a larger group now imposes a spectrum of approaches ranging from transactional to transactional with group testing, to a group approach and to a formulaic approach. This session will explore the practical challenges created particularly when it comes to tax neutrality and a level playing field, and the policy grounds on which these differences may be justified.