We are pleased to announce that the 2024 Cahiers are published and can be accessed online via the IFA website!The subjects this year are:
• Subject 1: Finding the meaning of nexus for taxes – past, present and future
General reporters: Prof. Johann Hattingh (South Africa) and Prof. Peter Hongler (Switzerland)
Nexus is a term commonly used in international law to determine whether there is sufficient connection between a person, property, or an activity with a State so that the State has prescriptive jurisdiction to legislate. The goal of the national reports and the general report was to assess what nexus means, as well as its rationale, in the context of the main tax obligations in the reviewed States. In addition to the general and national reports, an international law expert - Professor Cedric Ryngaert – wrote an international law report. General conclusions falling into five categories were derived from this unprecedented comparative analysis, including that evidence of State practice points to there being a limit on prescriptive State jurisdiction in tax matters in countries where international law is constitutionally entrenched.
• Subject 2: Practical approaches to international tax dispute prevention and resolution
General reporters: Prof Jan de Goede (Netherlands) and Samuel Maruca (USA)
“Practical approaches to International Tax Dispute Prevention and Resolution” focuses on issues arising in cross-border corporate taxation. The topic was very broadly defined, covering all tax dispute prevention and resolution mechanisms (domestic and international) applied from a tax audit up to and including binding arbitration, to enable many IFA branches to participate. Dual reporting was strongly recommended to have both a taxpayer and a tax authority perspective. An unprecedented number of 46 reports were received (44 country branch reports – amongst which many from branches in developing countries- and an OECD and an EU report) and more than 20 mechanisms were evaluated and recommendations to improve these provided.
These key topics will be covered at the IFA Annual Congress in Cape Town, taking place from October 27-31, 2024. For more details on the program and registration, please follow the link.
The complete Cahiers are published online, featuring general reports, full branch reports, biographies, and directives. IFA members can access the digital version through the secure section of the IFA website.
To explore this valuable academic resource, simply login to the IFA website as a member.