IFA International Conference: Practical aspects of the application of the double tax treaty between Germany and Poland
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 Krakow, Poland on September 25, 2023. The event will be held in English.
Organizing Committee
• Prof. Dr. Christian Kaeser, President of the Board at IFA Germany, Head of Tax at Siemens AG
• Prof. Dr. Xaver Ditz, Partner at FGS
• Mr. 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
Agenda:
24 September 2023
18:30 Opening lecture and dinner
25 September 2023
10:00-11:00 Registration
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
11:15-12:45
Chair:
• Prof. Dr. Adrian Cloer, Honorary Professor at the European University Viadrina, Honorary Judge at the Higher Regional Court of Brandenburg, Co-editor of Jamrozy/Cloer Commentary on GermanPolish Double Tax Convention
Speakers:
• Dr. Marcin Lachowicz, Polish Ministry of Finance, Tax Policy Department (in charge for DTT negotiations and exchange of information), Chair of Polish GAAR Panel
• Dr. Jakub Jankowski, Polish Ministry of Finance, Income Tax Department
• Mr. Arkadiusz Bakowski, Head of global tax at BASF ECMS Group
• Dr. Monika Wünnemann, Head of Tax at German Federation of Industries
• Dr. Wojciech Sztuba, President of the Board at IFA Poland, Partner at TPA Poland
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
13:00-14:30
Chair:
• Prof. Dr. Xaver Ditz, Partner at Flick Gocke Schaumburg in Bonn/Duesseldorf and professor at the University of Trier
Speakers:
• Prof. Dr. Robert Ullmann, University of Augsburg, member of the advisory commissions for the EU Dispute Resolution Mechanism
• Ms. Helena Radzięciak, Polish Ministry of Finance, Head of Unit (directly supervising currently pending Polish MAP proceedings)
• Dr. Monika Laskowska, Warsaw School of Economics, Ex-Deputy Director at Direct Taxes Department in the Ministry of Finance (dealing with TP and AOA), board member at IFA Poland
• Dr. Michael Hoelzl, Head of Tax, Customs & Branch Management at Siemens Energy
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
14:30-15:30 Lunch
Part. III. Impact of changes in the business and regulatory environment
15:30-17:00
Moderator:
• Prof. Dr. hab. Krzysztof Lasiński-Sulecki, Professor at the University of Torun, Member of the Board of IFA Poland
Paneliści:
• Dr. Filip Majdowski, Member of the Steering Group of the OECD/G20 Inclusive Framework on BEPS, Adviser to the Polish Ministry of Finance on International Tax Law
• Prof. Dr. Christian Kaeser, President of the Board at IFA Germany, Head of Tax at Siemens AG
• Mr. Cezary Krysiak, Polish Ministry of Finance, Head of TP unit at Direct Taxes Department
• Ms. Patrycja Brzostowska, Head of Tax at Getir Group
• Ms. Dominika Tyczka-Szyda, Tax adviser, Partner, Head of Legal & Tax Consulting Department in Wroclaw responsible for TP team in Rödl & Partner Poland
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. Christian Kaeser, President of the Board at IFA Germany
Dr. Wojciech Sztuba, President of the Board at IFA Poland
Registration and fees
EUR 150 / PLN 675 (VAT included) registration fee applies to IFA Members
EUR 200 / PLN 900 (VAT included) 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.
If you are interested in paying via PayPal, Przelewy24 platform and/or would like to get a proforma invoice for your payment, we encourage you to register below:
- payment in PLN: https://app.evenea.pl/event/ifa-cracow-2023
- payment in EUR: https://app.evenea.pl/event/ifa-cracow-2023-euro
If you are interested in payment in a form other than those listed, please send your application to e-mail: marketing@tpa group.pl
Agenda: download (pdf)
Event Partners:
