Annex 7 – GC/GA meeting Madrid 28 September 2016
Annual Report of the Secretary General 2015/2016
Dear fellow IFA Members,
2015 was memorable for its successful Annual Congress in Basel with more than 2.250 participants
including accompanying persons. The highlights of the Basel Congress of IFA since September 2015 are
summarised hereafter.
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Basel Congress (69th Congress, 30 August – 4 September 2015)
IFA thanks Maurus Winzap, Chair of the IFA 2015 Basel Congress, and his Organising Committee, Erich
Ettlin (Secretary/Treasurer), Hubertus Ludwig, Daniel Schafer and Pascal Taddei.
The Swiss Branch organized an excellent and successful Congress for 2.285 participants including
accompanying persons. Memorable events include the Opening Ceremony depicting Switzerland in all
his facets, the cultural evening at the various museums and the magnificent Gala Dinner with a fairy tale
show topped up by dancing.
Scientific Programme
IFA would like to thank everyone involved for their excellent contributions to the Scientific Programme
of the Basel Congress.
Robert Danon (Switzerland) was the General Reporter on Subject 1, “Tax incentives on Research &
Development (R&D)”. Stephen Shay (USA) acted as Chair. The Panel consisted of David Bradbury (OECD),
Barbara Kessler (Switzerland), Raymond Luja (Netherlands), Belema Obuoforibo (IBFD) and Manuel Tron
(Mexico). Thierry Obrist (Switzerland) acted as Secretary.
“Practical protection of taxpayers’ fundamental rights” was the topic of 2015 Subject 2 with Philip Baker
(United Kingdom) and Pasquale Pistone (Italy) as General Reporters, Michael Beusch (Switzerland) as
Chair and Susanne Raas (Switzerland) as Secretary. The Members of the Panel were: Beric Croome
(South Africa), Masato Ohno (Japan) and Luis Eduardo Schoueri (Brazil).
Seminar A, “Patent Boxes (Companion to Subject 1)”, was chaired by Maria Teresa Soler Roch (Spain).
Paolo Arginelli (Italy), Cécile Brokelind (Sweden), Robert Danon (Switzerland), Achim Pross (OECD) and
Michiel Van Kempen (Netherlands) were Members of the Panel. Elizabeth Gil Garcia (Spain) acted as
Secretary.
Seminar B dealt with “The taxation of expatriates”. Chair was Carol Tello (USA) and Members of the
Panel were Olivier Dauchez (France), Michael Hildebrandt (Switzerland), Pilar Molina (Spain), and Martin
Reinhold (Germany). Tatiana Falcão Octaviano (Brazil) acted as Secretary.
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“Cross-border supply of services and VAT/GST: Development of IFA” was the topic of Seminar C, chaired
by Philip Robinson (Switzerland). Panel Members were Piet Battiau (OECD), Rita De La Feria (Germany),
Thomas Ecker (Austria), and Karl Heinz Haydl (Germany) whilst Clara Bodemann (Switzerland) acted as
Secretary.
Seminar D, “Practical protection of taxpayers in the exchange of information process (Companion to
Subject 2)”, was chaired by Jennifer Roeleveld (South Africa). The Panel Members were Philip Baker
(United Kingdom), Monica Bhatia (OECD), Ernst Czakert (Germany), Addy Mazz (Uruguay) and Xavier
Oberson (Switzerland). Interventions were done by Alan Granwell (USA). Craig West (South Africa) acted
as Secretary.
The topic of Seminar E was “Cross-border mergers of companies”, chaired by Pascal Hinny (Switzerland).
Panel Members were Lydia Challen (United Kingdom), Christian Kaeser (Germany), Peter Ni (PRC), David
Saltzman (USA) and Paul Sleurink (Netherlands). Arnaud Martin (Switzerland) acted as Secretary.
Seminar F “IFA/EU: “State Aid Review as a means to combat aggressive tax planning”” was chaired by
Luc De Broe (Belgium). The Panel was made up by Conor Quigley (United Kingdom), Karl Soukup (EU),
Rita Szudoczky (Hungary) and Isabel Verlinden (Belgium). Joris Luts (Belgium) was the Secretary.
Seminar G dealt with “IFA/OECD”. Wolfgang Schön (Germany) acted as Chair and Peter Hongler
(Switzerland) as Secretary. Krister Andersson (Sweden), Marlies De Ruiter (OECD), Ron Durand (Canada),
Liselott Kana (Chile) and Robert Stack (USA) were Members of the Panel.
Stephen Bowman (Canada) acted as Chair on Seminar H “The taxation of global families” and Claudia
Suter (Switzerland) as Secretary. Eric Ginter (France), Sushil Lakhani (India), Dianne Mehany (USA) and
Michael Pfaar (Singapore) were the Panel Members.
“Effectiveness of the participation exemption” was the subject of Seminar I, chaired by Georg Kofler
(Austria). Panel Members were: Gauthier Blanluet (France), Eric Kemmeren (Netherlands), Ruth Mason
(USA) and Toshio Miyatake (Japan). Florian Regli (Switzerland) was the Secretary.
At Seminar J “Recent developments in international taxation” was the theme with Daniel Gutmann
(France) as Chair. Panelists were Herman Bouma (USA), Jean Blaise Eckert (Switzerland), John Lorito
(Canada), Arne Schnitger (Germany), Chris Taylor (Australia), Mike Williams (United Kingdom) and
Bartjan Zoetmulder (Netherlands). Secretary was Luzi Cavelti (Switzerland).
The topic of Seminar K was “Practical protection of taxpayers in the tax litigation process (Companion to
Subject 2)”, chaired by Justice Tony Pagone (Australia). Panel Members were Robert Attard (Malta),
Emmanuelle Cortot-Boucher (France), Justice Klaus-Dieter Drüen (Germany), Justice Vineet Kothari
(India) and Justice Gerald Rip (Canada) with interventions of Philip Baker QC (United Kingdom) and Peter
Connors (USA). Filip Debelva (Belgium) acted as Secretary.
Seminar L treated “Timing issues in the application of tax treaties”. Chair was Josef Schuch (Austria). The
Panel Members were Laila Benchekroun (Morocco), Jacques Sasseville (OECD), Mario Tenore (Italy) and
Joanna Wheeler (IBFD). Jérôme Bürgisser (Switzerland) acted as Secretary.
Special luncheons
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On Monday 31 August 2015, the Government Luncheon took place with approximately 80 participants
and the event was attended by IFA’s President Porus Kaka and Stef van Weeghel, Chair of the PSC. The
Corporate Tax Officers Event took place on the same day and was attended by IFA’s General Treasurer
Jos Beerepoot. Approximately 90 participants attended. Finally, the luncheon for Academics was also
organized on Monday 31 August 2015 day, with around 80 attendees and attended by IFA’s Secretary
General Han Kogels and Jean-Blaise Eckert, Deputy Secretary General.
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IFA Branches
At its meeting during the Basel Congress, the General Council of IFA accepted the application of a new
IFA Branch in Barbados. IFA has now 68 Branches and several countries have expressed their interest in
establishing IFA Branches. Membership of IFA now stands at 12.392 (per 23 May 2016) from 113
countries.
Regional and bilateral IFA Conferences
Since the 2015 Basel Congress many IFA Branches organized successful conferences at local or regional
level. The complete list is published on the website up to the extent that the activities were
communicated to Central IFA. Hereunder some examples of regional meetings and bilateral
conferences, as well as meetings of organizations with which IFA has a standing cooperation, most of
them attended by representatives of Central IFA:
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23 October 2015, Jubilee Conference with representatives from all Portuguese speaking
countries worldwide, on the occasion of the 50th Anniversary of the Portuguese Branch, Lisbon,
Portugal
Attended by Han Kogels
4-6 November 2015, Bilateral meeting Germany and China PRC, Beijing, China PRC
24 February 2016, Bilateral meeting Brazil and USA, Biltmore Miami, USA
25-26 February 2016, 2016 IFA USA Annual Conference, Biltmore Miami, USA
Attended by Porus Kaka
21-22 April 2016, Nordic IFA Conference Denmark, Finland, Norway and Sweden, Berlin,
Germany
Attended by Bertil Wiman
29-30 April 2016, Trilateral meeting Austria, Germany and Italy, Vienna, Austria
4-6 May 2016, 8th Latin American Regional Conference, Lima, Peru
Attended by Andres Valle Billinghurst
12-13 May 2016, 2016 Asia-Pacific Regional Tax Conference, Seoul, Korea, Rep. of
Attended by the Executive Board and many members of the Executive Committee
19-20 May 2016, 10th Asia/Africa IFA Conference, Mauritius
Attended by Porus Kaka
2-4 June 2016, 2016 Annual Congress of the European Association of Tax Law Professors EATLP,
Munich, Germany
Attended by Han Kogels
3-4 June 2016, Trilateral meeting Belgium, France and Luxembourg, Nice, France
More detailed reports on these successful Regional Conferences can be found on the IFA website.
The following local and regional conferences will take place in 2016/2017:
23-24 September 2016, Bilateral meeting Italy and USA, Barcelona, Spain
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22-23 February 2017, 2017 IFA USA Annual Conference, New York, USA
24 February 2017, Bilateral meeting Switzerland and USA, New York, USA
31 May – 2 June 2017, 9th Latin American Regional Congress, Buenos Aires, Argentina
- Executive Committee (EC)
The EC met in Basel (30 August 2015) and in Seoul (14 May 2016).
EC meeting Basel August 2015
At the 2015 IFA Congress in Basel the following EC Members retired from office.
Detlev Piltz (Germany)
Beatrice Deshayes (France)
Hans Severin Hansen (Denmark)
IFA is grateful for all the work they did during their term. The following persons were appointed in the
EC at the Basel Congress:
Niv Tadmore (Australia)
Christian Comolet Tirman (France)
Christian Kaeser (Germany)
David Jin-Young Lee (Rep. of Korea)
The following persons were re-appointed for another term of two years:
Porus Kaka (India) as President
John Nicolai, 2nd Vice President (USA)
Brian Schneiderman (Canada)
Sushil Lakhani (India)
José Palacios Perez (Spain)
André Oliveira (Brazil)
Victor Matchekin (Russia)
EC meeting May 2016
At its May 2016 meeting the EC approved the financial report 2015, provided by Jos Beerepoot, General
Treasurer of IFA, in which a small deficit was reported due to the fact that (i) in comparison with 2014
there is a slightly lower income on membership fees, although the 2015 level of income out of fees is
the level which has been regular over the years and (ii) a contribution of 50.000 Euro (instead of 100.000
Euro) from the Swiss Branch because the surplus of the Basel Congress is relatively modest in
comparison with the Copenhagen and Mumbai Congresses.
Further, the cost saving concerning the digitisation of the Cahiers is still modest for 2016 because of the
developing cost of the digital structure. It is expected that 2017 will see some more saving. The opt-in
opt-out option will remain available for the printed Cahier of the General Reports.
The financial report will be submitted to the General Council, for final approval by the General Assembly
at their combined meeting during the 2016 Madrid Congress.
After ample consideration the EC decided to allocate the IFA Congress of 2023 to Lisbon, Portugal.
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- Permanent Scientific Committee (PSC)
The PSC met in Basel (30 August 2015) and in Madrid (4-5 February 2016).
PSC meeting Basel August 2015
Peter Barnes (USA) succeeds Peter Blessing. The PSC thanks Peter Blessing for his valuable input over
the years and wishes him a successful term as President of the USA Branch.
Concerning the further composition of the PSC the following persons were re-appointed for a two years
term:
Stef van Weeghel (Netherlands) as Chair
Daniel Garabedian (Belgium)
Gauthier Blanluet (France)
Keiji Aoyama (Japan)
Dariusz Wasylkowski (Poland)
Krister Andersson (Sweden)
The General Council decided to anticipate for the large number of retiring PSC members in 2016 and
appoint additionally in the PSC:
Miranda Stewart (Australia)
José Carlos Silva (Mexico)
Philip Kermode (EU) has moved on to another position within the European Commission and was be
succeeded by Valère Moutarlier (EU) as ex officio member of the PSC. The PSC thanks Philip Kermode for
his valuable contribution. Finally, the UK Branch appointed Murray Clayson as its co-opted member for
the 2019 London Congress.
PSC meeting Madrid February 2016
At the end of the Madrid Congress Fernando Serrano Anton (Spain) will retire and Mexico will nominate
its co-opted member for the 2020 Congress.
At its meetings, the PSC extensively discussed the Subjects and Seminars for the Congresses 2016-2019.
Valuable contributions were made by the General Reporters, the Chairs of the Sessions and the
members of the Programme Working Group.
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David R. Tillinghast Research Program
After we restructured the David R. Tillinghast Programme in 2011, IFA received seven applications from
across the globe for organizing an academic or scientific conference on matters on international or
comparative tax Law. The Programme Working Group (PWG), extended with Dariusz Wasylkowski
(Poland) and Craig Elliffe (New Zealand), proposed to award the application from the Centro de Estudios
Tributarios from the University of Chile on “The new international tax cooperation paradigm: Impact on
domestic tax regimes and the cross-border allocation of taxing rights”. The conference took place in
November 2015 and was a great success. On behalf of IFA, Scott Wilkie, Vice-Chair of the PSC, attended
this conference.
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Publications and website
2015 Cahiers
Volume 100a of the Cahiers 2015 (Tax incentives on Research & Development (R&D)) includes a General
Report by Robert Danon (Switzerland), 39 Branch Reports and the EU Report.
Volume 100b (Practical protection of taxpayers’ fundamental rights) counts 42 Branch Reports, next to
the General Report by Philip Baker (United Kingdom) and Pasquale Pistone (IBFD/Italy).
Digitization of the IFA Cahiers
In line with the approval by the GC/GA of the step-by-step digitization of the IFA Cahiers, as of 2016 the
printed publication of the Cahiers consists of the General Reports of both Subject 1 and Subject 2,
together with short biographies of all Branch Reporters. By continuing the printing of the General
Reports, IFA will sustain the legacy of the Cahiers.
The digital publication consists of the General Reports as well as all Branch Reports including the
biographies. The digital publication will be made available through the websites of IFA, of its sister
organisation IBFD and of the publisher.
Website and Congress App
The IFA website provides up-to-date information on the activities of all IFA Branches and of Central IFA.
Also the YIN website is technically accessible to all members.
The Congress App provides all information on the scientific and social program as well as on Congress
participants and speakers. The App has become a traditional feature during the Annual IFA Congresses,
which is highly appreciated by the attendants.
Global IFA Newsletter
The past year saw 6 digital issues of the Global IFA Newsletter. The Editorial Team, enthusiastically led
by Cécile Riphagen (General Manager of IFA) and including Maikel Evers (Netherlands), Rajeshsharma
Ramloll (Mauritius) and Paresh Parekh (India), covers the IFA activities taking place in all regions and
keeps track of important developments in the world of international taxation. Interviews with several
the OECD and IFA members on current issues have been published and the YIN Community and the
Women in IFA Network (WIN) have separate sections providing all information on their activities.
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Young IFA Network (YIN)
IFA’s young community is thriving as more and more Branches have become interested in YIN. More
than 43 IFA Branches have YIN Representatives that promote and coordinate the YIN activities in their
Branches.
IFA President YIN Scientific Award
In 2016 the Jury, chaired by Robert Danon (Switzerland), received 5 applications. The Jury concluded to
award the prize to Blazej Kuzniacki (Poland) for his work entitled “The Need to Avoid Double Economic
Taxation Triggered by CFC Rules under Tax Treaties, and the Way to Achieve it”.
The Jury further decided to grant the work “Chapter 5 The OECD Plan to Neutralise the BEPS Effects of
Hybrid Mismatch Arrangements: Challenges Ahead?” written by Lucas Carvalho (Brazil) with an
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honourable mention. The Chair of the Jury will mention this in his speech during the YIN Meet & Greet
Reception on the 70th Madrid Congress on 25 September 2016.
YIN activities
During the 2015 Basel Congress successful and well attended YIN activities have been organized, such as
the YIN Seminar and the YIN Party. YIN has a separate section in the quarterly IFA Newsletter. The YIN
Community is present on LinkedIn and on Facebook. Ten years after its initiation, YIN has grown into a
robust network developing activities in a growing number of Branches. The YIN Committee gets full
support of Central IFA in its actions to make IFA even stronger in the future.
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Women IFA Network (WIN)
2015 saw the consolidation of the Women IFA Network (WIN). IFA strives at being representative, not
only for the four corners of the globe but also for a dynamic international tax community. Ten years ago
talented young professionals in the field of international taxation joined forces and founded the by now
established Young IFA Network (YIN). Now the Women of IFA Network (WIN) has been established to
represent and connect the many professional women working in international tax.
In recent years the female membership of IFA has grown to more than 2.000 female members across
the globe; there is a fast growing awareness of the significance of professional women in international
taxation. Trying to connect these women to create a network and discuss common issues, a WIN activity
will again be organized at the 2016 Madrid Congress.
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IFA Prizes
Mitchell B. Carroll Prize
The Jury for the MBC Prize received 12 entries from Austria (3x), Croatia, France, Germany (3x),
Netherlands (3x) and the USA. We are very grateful for the time and efforts spent by the Jury members
in meeting this daunting task. The Jury concluded to award the 2016 Prize to Hermann Peyerl (Austria)
for his work “Die Verlagerung von Einkünften; Einkünftezurechnung im nationalen und internationalen
Steuerrecht”.
Honourable mentions were granted to Ruben Martini (Germany) for his work “Der persönliche
Körperschaftsteuertatbestand; Eine rechtsvergleichend-historische Analyse der Bestimmung von
eigenständig steuerpflichtigen Personenvereinigungen” and to Alexander Bosman (Netherlands)
for his work “Other Income under Tax Treaties; An Analysis of Article 21 of the OECD Model
Convention”.
Maurice Lauré Prize
The Jury for the ML Prize received 1 entry from Germany. They unanimously concluded to award the
2016 Prize to Thomas Wiesch (Germany) for his work entitled “Die umsatzsteuerliche Behandlung der
öffentlichen Hand”.
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Closing remarks
The past year was noteworthy with a successful Congress in Basel hosted by the Swiss Branch and a
growing number of regional, bi-lateral and tri-lateral conferences. And the Young IFA Network has set
important steps to involve the young IFA generation in achieving our objects. We are most grateful for
the dedication and enthusiasm of so many Members who spend part of their precious time to
contribute to IFA – you are making IFA the unique independent platform for study, research and
dialogue on international taxation.
This year we will say farewell to Thea van Dijk who joined the IFA General Secretariat in 1976 and has
been working closely together with the Organizing Committees of our Annual Congresses and the
reporters for the Cahiers. We want to thank her for all the valuable work she has done for IFA and we
wish her all the best for the future.
A personal note at the end of this report. After eight years in office as Secretary General of IFA, I will
retire at the end of the 2016 Madrid Congress. It was a great pleasure and privilege serving IFA.
I want to thank everyone for the excellent cooperation and friendship I enjoyed, in particular my fellow
board members through these years and the ladies of the General Secretariat who are the core of our
IFA organization. With great confidence I hand-over my tasks to my successor Jean-Blaise Eckert whom I
wish success.
July, 2016
Prof. Dr. Han Kogels
Secretary General IFA
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