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Global perspectives on tax planning challenges


Professor Giulio Allevato spoke of anti-abuse rules and tax planning challenges in three different conferences held at Colombia.

At the XII International Tax Meeting Conference, “Tax planning challenges in the face of specific anti-abuse rules”, held in Bogota at Universidad Externado, Professor Allevato joined various international speakers to address the topic from a comparative European, American and Colombian perspective, taking into account legal tax, corporate, and criminal viewpoints.

In particular, Professor Allevato -whose research mainly focuses on the regulatory function of taxation, tax compliance legal framework,  tax issues related to the Digital Economy, and legal implications of tax risk management- observed how cooperative tax compliance programs, which have already been implemented by over twenty-five OECD countries, are leading to a radical change in the corporate tax compliance framework.

“Through such programs, the traditional ex-post confrontation relationship between tax authorities and corporate taxpayers is progressively turning into an ex-ante cooperation mechanism, where the two parties are eager to jointly work to achieve advance solutions to tax qualification and tax application issues.  This new tax compliance framework is aimed at making both corporate taxpayers and tax authorities better off in terms of, respectively, more legal certainty about the tax treatment of their transactions, and a more efficient use of audit and assessment resources. In order for these programs to be successful, it is critical that taxpayers adopt and develop an internal system of tax risk control (so-called “Tax Control Framework”), and that tax authorities are able to effectively diversify corporate taxpayers based on their tax risk profile”, explained Professor Allevato in his intervention. Finally, he observed how, in such a new paradigm, the role of corporate tax directors is necessarily increasing in terms of involvement in strategic decision-making and internal prestige.


During his visit to Colombia, Professor Allevato also joined a roundtable organized by the Instituto Colombiano de Derecho Tributario and the University of Miami on Double Tax Treaties with the United States. He joined Patricia Brown, Director of the Tax LLM Program, Lecturer in Law, University of Miami School of Law, and Pablo Hernández González-Barreda, Professor of Tax and Financial Law, Comilla-ICADE to discuss the tax policy ratio of the double tax treaty between Italy and the US and possible future scenarios in light of recent and perspective amendments to the domestic tax law of these two countries.

He finalized his trip to Colombia with a visit to Medellin for a conference organized by CETA (Centro de Estudios Tributarios de Antioquia) and ANDI (Asociación Nacional de Industriales), where he illustrated to local tax directors and practitioners the main features of cooperative tax compliance programs implemented by OECD countries.