Location, Location, Location:
• Using holding & finance companies to minimise the global tax burden

The UK as a Holding Company Jurisdiction:
• Opportunities & pitfalls under the new regime

European and UK Case Law Update Session:
• The impact on the UK as a holding company regime
• Cases from Cadbury Schweppes to Vodafone 2

Should I Stay or Should I Go?
• The pros & cons of corporate redomiciliation

How & Why to Set up in a New Jurisdiction:
Practical advice on opportunities & advantages in:
• Benelux • Channel Islands • Cyprus
• Ireland • Isle of Man • Luxembourg
• Madeira • Malta • Netherlands
• Switzerland


SPECIAL HIGHLIGHT
The Brit Insurance Redomiciliation Case Study
• Rationale for change
• Principles of design
• Selecting a parent company location
• Jurisdiction shopping

08.30 – Registration & Coffee

09:00 – Chairman’s Opening Remarks
Paul Smith
Head of International Tax
GRANT THORNTON


09:10 – 09:50
Location, Location, Location -
Using Holding and Finance Companies
to Minimise the Global Tax Burden
• Key considerations when designing the optimal structure
• Flat structure vs. many holding companies?
• Onshore or offshore?
• Moving from the theoretical to reality
Kate Alexander
Partner, International Tax Services
ERNST & YOUNG


09:50 – 10:30
The UK as Holding Company Jurisdiction –
Opportunities & Pitfalls under the New Regime
• Foreign Profits
• Debt Cap issues
- exemptions for finance companies
- use of UK finance companies to
minimise debt exposure
• Dividend Exemptions
• Substantial Shareholdings Exemption
• CFC issues
Peter Cussons
International Corporate Tax Partner
PRICEWATERHOUSECOOPERS


10:30 – Coffee Break


10:45 – 11:25
European and UK Case Law Update Session –
The Impact on the UK as a Holding Company Regime
• CFCs– Where are we?
- The starting point: the ECJ test in Cadbury Schweppes
- Domestic developments in Vodafone 2
- Where does this leave the UK?
• Group relief
- The starting point: the ECJ test
- Recent developments
• The impact of domestic litigation
- Privilege
- “Unallowable purpose”
Liesl Fichardt
Partner
BERWIN LEIGHTON PAISNER LLP


11:25 – 12:05
CASE STUDY
The Brit Insurance Holding Company Relocation
• To redomicile or not to redomicile
- Rationale for change
• Principles of design:
- there was more than tax
• Considerations when selecting a parent company location:
- EU or not?
• Comparison with other jurisdictions
- what mattered
• Conclusion
Neil Sharman
Head of Tax
BRIT INSURANCE


12:05 – 12:40
INDUSTRY PANEL SESSION
Should I Stay or Should I Go? –
The Pros and Cons of Corporate Redomiciliation



Panellists:
Neil Sharman
Head of Tax
BRIT INSURANCE
Paul Morton
Head of Group Tax
REED ELSEVIER GROUP


12:40 – Networking Lunch

Jurisdictional Focus Sessions
(Covering the Regimes of More than 6 Tax Jurisdictions)

13:40 – 14:20
MADEIRA as a Holding Company Regime


14:20 – 15:00
CYPRUS as a Holding Company Regime


15:00 – Afternoon Refreshments


15:15 – 15:45
IRELAND as a Holding Company Regime


15:45 – 16:20
SWITZERLAND as a Holding Company Regime



16:20 – 16:55
NETHERLANDS & LUXEMBOURG as a Holding Company RegimeS



16:55 – 17:30
Comparative Analysis of the Different Jurisdictions
(Ireland, Switzerland, Benelux)
• Tax exemptions available for holding companies
• Withholding taxes, CFC and TP issues compared
• Locations suitable for HQ operations as distinct from a holding company location
• Incentives for relocation of staff
• Suitability for group treasury & IP operations
• Ease of move
• Other jurisdictions:
- Malta
- Isle of Mann
- Channel Islands
Paul Smith
Head of International Tax
GRANT THORNTON

17:30 – Close of Conference

Peter Cussons, International Tax Partner; Head of the Foreign Tax Desks, PricewaterhouseCoopers

Paul Smith, Client Service Director, Grant Thornton

Liesl Fichardt, Partner, Berwin Leighton Paisner

Kate Alexander, Partner, Ernst & Young

Neil Sharman, Head of Tax, Brit Insurance

Paul Morton, Head of Group Tax, Reed Elsevier

David Norton , Partner, Deloitte

Helen Blenkinsop, Group Tax Director, Informa Group Plc

Paul Reck, Tax Partner, Deloitte (Ireland)

Peter Brulisauer, Partner, Tax - Financial Services, Ernst & Young (Switzerland)

Marcel Buur, Partner, Loyens & Loeff