Summary - ADIT International Tax Webinar

Led by experts from across tax practice, industry and government and covering wide-ranging technical subjects across multiple tax jurisdictions, our ADIT International Tax Webinars are a great way to keep up with the latest global tax developments.

Join us for our next webinar on 16 October, where our speaker will be looking at entity characterisation and hybrid outcomes.

Entity characterisation is one of the gateway issues in international taxation because the same legal vehicle may be treated as fiscally transparent in one jurisdiction and opaque in another, with potentially very different consequences.

This webinar will examine how such conflicts should be analysed systematically, moving beyond entity labels and posing three distinct questions: legal form, domestic tax treatment and treaty entitlement.

Entity characterisation and hybrid outcomes (without TP)

Friday 16 October | 11.30 BST | 12.30 CEST | 16.00 IST

with Angelo Chirulli

In this webinar, our speaker will cover:

Transparent vs opaque entities and conflicts of qualification
Hybrid mismatches as a conceptual problem, not a computational one
Treaty interaction and the risk of double taxation or double non-taxation
Exam focus: critical analysis of classification and its consequences

Through practical and case-led examples, the session will explore how differences between jurisdictions can produce conflicts in taxpayer identity, income character and timing.

We will distinguish ordinary qualification conflicts, and consider why treaty relief, unilateral credit relief or MAP may not automatically eliminate the resulting double taxation or withholding friction.

This session will also assist ADIT students on how to identify the domestic classifications first, determine who is actually taxed and on which income item, establish treaty entitlement, select the relevant distributive article, diagnose the precise mismatch and only then consider relief or counteraction. Worked scenarios and an exam-style exercise will be used to develop the critical, fact-led reasoning expected in a high-quality ADIT answer, rather than a descriptive discussion of transparency and hybridity.

You can also submit questions for a live Q&A!