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Indirect Tax and VAT Implications for U.S. Companies in a Post-Brexit World

10.07.20

Any U.S. company active in the European Union (EU) have been able to participate and benefit from the single most important economic feature of the EU - the free movement of goods, capital and people. As a result of the Brexit withdrawal agreement and the end of the transition period on December 31, 2020, the single market concept will cease to apply for companies in the United Kingdom (UK) and EU member state companies active in the UK marketplace as of January 1, 2021. This will have a profound impact on U.S. entities active in the EU and UK for Value-Added Tax (VAT) purposes, custom duties (import/export), and logistics, which will need to be addressed urgently.

Join our international speaker panel consisting of EU VAT and indirect tax specialists from Azets Holdings Ltd., BPM LLP, ESJ Financial Engineering, GMBA, KBHT, and Pirola Pennuto Zei & Associati, as they explain the practical effect of the UK leaving the single market and the potentially adverse results which require urgent attention for U.S. companies active in the EU. The panel will guide you through a case study focusing on the treatment of European services and sales of products, including a license arrangement before and after January 1, 2021. An example of questions to be addressed include:

  • Will the change as of January 1, 2021 require new VAT registrations for U.S. companies or their EU subsidiaries?
  • What impact will new Custom duties have on the flow of goods between the UK and the EU, and what can be done now to avoid immediate negative consequences?
  • What (new) compliance filings or reporting requirements will come into effect per January 1, 2021 for U.S. or EU based entities active in the UK?
  • What best practices are there to navigate the new landscape? Will there be a new trade agreement between the EU and the UK applicable after January 1,2021, and if so, how will it look? Can we predict how a” no deal” scenario would look like?

Date: Wednesday, October 7, 2020

Time: 
Presentation, 8:00 AM – 8:45 AM PT 
Q&A with Panel, 8:45 AM – 9:00 AM PT 

Speakers:

Frank van Hulsen, Managing Director, International Tax
BPM LLP | San Jose, CA 

Frank has over 30 years of experience in international corporate and VAT tax matters in Europe and US. During his career initially at one of the big four advisory firms, he has advised large multinational companies on their international structures, including IP ownership and M&A transactions. 

In recent years he has focused on US companies, mainly in Silicon Valley advising on efficient tax structures taking into account US legislation and EU directives and their impact on US companies active in Europe. Frank has a tax law degree from the University of Amsterdam, school of law and is based in San Jose, CA. 


Andy Dawbarn, Partner, VAT
Azets | London, UK 

Andy has spent over 30 years in VAT. He leads the direction and delivery of VAT and other indirect tax advisory services. Andy is CTA qualified and manages a varied portfolio, working with UK-based and international businesses alike. Andy’s role includes providing advice on indirect tax services, new legislation and operational compliance. His sector expertise spans financial services, property and construction, academies and not for profit. 


Greg Mayne, Director of VAT
Azets | Maidstone, UK 

Greg is a Director for VAT based in the South East of England. He provides both the strategic aspects and delivery of VAT advice to his clients. Greg’s well-established client portfolio encompasses businesses at all stages, from start up to international multi-location corporations. Greg is a true problem solver and he really enjoys getting stuck in complex VAT issues. This makes Greg extremely proactive, and he can often identify problems before they arise. Greg’s specialisms lie in the property industry and charities sector, but particularly in international trade where his skills in providing advice concerning VAT and customs duties come into play. 


Lucy Sutcliffe, Director of National Customs Duty, Tax and Advisory
Azets | Peterborough, UK 

Lucy specializes in customs and excise duties providing technical advice, guidance and streamlining solutions for businesses involved in the movement of goods, imported into and exported from the UK, the EU and the rest of the world. She also provides customs related advice on the potential impact of the UK’s departure from the EU, the end of the transition period, and then imminent negotiations as to the lasting future trading relationship with the EU and the rest of the world. Lucy has extensive experience of the customs trade and international trade environments, and has worked closely at senior government levels in various overseas jurisdictions advising on upstream customs interdiction, financial crime prevention, customs policy, and facilitating customs training to key partners. 


Kirsten Deij, MSc, Belastingadviseur/Tax Advisor, Indirect Tax
ESJ Financial Engineering | Breda, Netherlands 

Kirsten works as senior indirect tax manager for ESJ in the Netherlands with a strong focus on international VAT. Before his employment with ESJ, Kirsten used to work within a Big 4 environment where he had a focus on assisting international clients with their EU expansion and optimizing their supply chain. Other focus areas are holding/financing companies and digital services.  


Philipp Berlin, Steuerberater/Cert. Tax Adviser
KBHT | Neuss, Germany 

Philipp is a certified tax adviser under the German tax consulting law, holds a Master in Fiscal Affairs (Dipl.-Finanzwirt) and is working for KBHT since 2014. Before working for KBHT, Philipp was a tax officer at the German fiscal authorities working in different positions such as the assessment of income, corporation, trade and value added tax, as well as doing tax audits. Philipp focuses on VAT and international taxation, and is part of KBHT’s international tax law department. He is supporting companies of nearly all sizes as well as private individuals regarding national and international tax matters. His work includes the support of tax audits and legal proceedings, preparation of tax returns and professional opinions as well as tax structuring projects. 


Laurent Dommergues, Director, Tax and VAT Specialist
GMBA Walter Allinial | Paris, France 

Laurent is an attorney member of the Madrid Bar Association and a former member of the Paris Bar Association. He specializes in Direct and Indirect International taxation of companies and has a specific expertise in the field of VAT. Laurent advises medium and large sized International companies operating in a wide range of industry and service sectors. He represents and defends his clients in tax disputes with the tax authorities.  


Stefano Cesati, Partner
Pirola Pennuto Zei & Associati | Milan, Italy 

Stefano graduated in Economics from Milan’s Università Cattolica, is registered with the List of Auditors (“Albo dei Revisori Contabili”), and the Association of Certified Public Accountants (“Albo dei Dottori Commercialisti”) of Milan. He advises major domestic and international companies in ordinary and extraordinary matters for leading international groups. He specializes in national and international VAT matters, and in e.invoicing and e.storage. He is a member of Commissione Fiscalità Internazionale (International Tax Committee) and publishes articles on VAT matters.