The impact of the reform of the US tax system on the possible scenarios of international taxation and, in particular for Europe and Italy, was the topic of the study day organized by the Studio Ludovici Piccone & Partners.
The works, introduced by Paolo Ludovici, founding partner of the Firm, Marzia Francisci, General Counsel of the American Chamber of Commerce in Italy, and by Jeffrey owens, Director of the WU Global Tax Policy Centre, are aimed at highlighting the important implications that the first real reform of the US tax system in the last 30 years could have on the value chain of multinational companies and on international tax scenarios.
La tax reform passed by the Trump administration in December 2017 it marks, in fact, a major overhaul of the US tax code and represents the culmination of a long process that can pave the way for multinational companies to establish (or increase) their presence in the United States or to reshape their value chain.
To this end, the US speaker Patrick C. Costello, Director of the Washington External Affairs Council on Foreign Relations, analyzed the economic directives of the Trump presidency in order to frame the US reform within a broader US fiscal and economic framework.
Andrew P. Solomon of Sullivan & Cromwell LLP and Sam Maruca of Covington and Burling LLP therefore focused on the innovations introduced by the reform, on their impact on the current international tax scenario and on the first reactions of the American economy, starting with US multinational groups.
The reactions in the international and European spheres were, however, at the center of the session chaired by Tim Brierley, Global Tax Director of SABIC, Vieri Ceriani, Advisor on Fiscal Policies to Italy's Minister of Economy and Finance and CEO of SOSE, Fred Lo, VP , Global Head of Tax of Yanfeng Global Automotive Interiors, Xavier Oberson, Professor in Swiss and International Tax Law at the University of Geneva and Zahira Quattrocchi, Group Tax Director of the Barilla Group.
In order to understand how the implementation of the Trump reform will affect the relationship with the tax administrations of emerging economies, as well as with the European Parliament, Max Lienemeyer, Head of Unit in charge of Tax Planning Practices of the European Commission, Alessandro Denaro, of the European Commission , Unit in charge of Tax Planning Practices and Raffaele Petruzzi, Managing Director of the WU Transfer Pricing Center,
Vienna University of Economics and Business, analyzed the European Commission's initiative in the field of state aid.
Such an initiative can be perceived as a challenge to US multinationals operating in Europe and can play a role in determining the outcome of relations between the interested parties. Finally considering that a different set of rules can cause uncertainty and possible cases of double taxation, Thomas Eisgruber, Head of Department, Taxation of Corporations, International Taxation and Audit, Bavarian Ministry of Finance, Carlos Perez Gomez Serrano, Director of Transfer Pricing Audits, Mexican Tax Administration Service (SAT) and Giammarco Cottani, L&P – Ludovici Piccone & Partners, verified the issues and legal tools available to resolve potential international tax disputes.
Collectively, all of the above topics were discussed by renowned international experts, ranging from international organizations, tax administrations, multinational companies, private firms and under the auspices of the Italian Branch of the American Chamber of Commerce. The event featured an in-depth discussion of key features of US tax reform, along with the expected reaction from multinational corporations and tax administrations.
