MIDDLE EAST/NORTH AFRICA TAX FORUM

18-20 October 2011

Istanbul, Turkey

The Middle East/North Africa Tax Forum brings together senior government officials in tax policy and administration from the MENA region, academic and industry experts, and representatives from international organizations. The Second Annual Meeting of the Forum is hosted by the Ministry of Finance of Turkey.

This Forum brings together these leaders, in a collaborative and neutral setting, to discuss solutions to common challenges and to share best practices in taxation. As many regional countries move towards a non-oil economy, and other countries see enhanced economic growth, we expect the Forum to evolve into a convenient platform where countries in the region share peer experiences, investigate issues of common concern, and gain insight about solutions used in more advanced economies. The purpose of the MENA Tax Forum is to bring the benefits of the successful regional programs conducted by ITIC in the Central Asia/East Europe, Asia Pacific and sub-Saharan Africa regions.

All Day / Delegates arrive in Istanbul
Upon Arrival / Delegates check-in
Address: Conrad Istanbul Hotel
Cihannuma Mah Saray Cd No5 Besiktas
Istanbul, 34353, Turkey
FORUM VENUE: Conrad Istanbul Hotel
Cihannuma Mah Saray Cd No5 Besiktas
Istanbul, 34353, Turkey
3:30 - 5:00 PM / Forum Registration for public sector participants
Pick up packet and materials
5:00-7:00 PM / Government Officials’ Forum
Chaired by: Director General, Directorate General of Revenue Policies, Ministry of Finance, Republic of Turkey
This forum event is for government officials to discuss, in private; their questions and concerns regarding the event.
·  Present the ad hoc Program Committee formed and explain the agenda process;
·  Suggest the formalization of the Steering Committee to guide future programs;
·  Gather feedback on the 2011 program;
·  Discuss/present a potential host for 2012. / Facilitators:
·  Mr. Salah Gueydi, Senior Tax Adviser, Ministry of Economy and Finance of the State of Qatar
·  Mr. Hafiz Choudhury, Program Advisor, International Tax and Investment Center (ITIC); Principal, M Group
5:30-7:00 PM / Forum Registration for private sector participants
Pick up packet and materials
7:30 -9:00 PM / WELCOME COCKTAIL
Hosted by the Ministry of Finance, Republic of Turkey
Forum Opening Address: / His Excellency Mehmet Simsek, Minister of Finance, Republic of Turkey (or his representative)
Welcome Remarks / ·  Mr. Daniel A. Witt President, International Tax and Investment Center (ITIC)
·  Mr. Moftah Jassim Al-Moftah, Director, Public Revenues & Taxes Department, Ministry of Economy and Finance of the State of Qatar*


9:00 – 9:45AM / Opening Address / His Excellency Mehmet Simsek, Minister of Finance, Republic of Turkey (or his representative)
Special Address
Role of Taxation and State Building: Tax and Democracy / Mr. Jeffrey Owens, Director, Centre for Taxation Policy and Administration, OECD
Welcome Remarks / Mr. Daniel A. Witt
SESSION I: TAX SYSTEM DESIGN IN MENA REGION
Chaired by: Mr. Jeffrey Owens
9:45-11:15 AM / Tax Policy Challenges and Trends in the MENA Region
What challenges do countries in the region face in 2011 and beyond, and what reforms should be considered
Key issues:
·  Need to diversify revenue sources
·  How to communicate with and be more responsive to taxpayers on tax policies in the context of changes in the region.
·  Experiences from the EU and how these can be of use in determining effective Taxation Policies / Presenter:
Mr. Antonis Kastrissianakis,
European Commission,
DG Taxation andCustoms Union; Directorate B - Security and Safety, Trade Facilitation and International Coordination Director - TBC
Discussants:
·  Mr. Finbarr Sexton, Tax Partner, Middle East Practice, Ernst & Young Qatar *
·  Representative from a resource rich country*
Representative from a non –resource rich state – e.g. Egypt or Tunisia*
·  Representative from major corporation with exposure across the region*
11:15AM / GROUP PHOTO
11:15-11:45 AM / TEA AND COFFEE BREAK
11:45-1:15PM / Breakout Session 1: Taxation on Financial Instruments in the Region: a Comparative Study
Chaired by: Mr. Abdelhamid Attalla, Middle East/North Africa Tax Director, GE
Venue: Conrad Istanbul Hotel
Room: Junior Ballroom
Issues and challenges of the Financial Sector:
·  Turkey as a case study (Strategy and action plan for Istanbul international finance center);
·  Creating an enabling environment for growth of the financial services sector;
·  Consider the indirect tax aspects:
o  international developments in the taxation of financial services under VAT, e.g. zero-rating B2B supplies;
o  VAT vs. separate taxes on financial services. / Presenter:
Mr. Alper BAKDUR, Head of Department, Ministry Of Development, Republic of
Turkey
Discussants:
·  Representative, JPMorgan Chase Bank*
·  Mr. Ufuk Ümit ONBAŞI (Deputy General Menager of İŞ Investment)
·  Mr. Ian Anderson, CFO and Tax Director, QFCA*
·  Mr. Naveed Jeddy, Ernst Young, Saudi Arabia
11:45-1:15PM / Breakout Session 2: Taxation of Business Income of International Companies from- Provision of Services in the Region
Chaired by: Mr. Finbarr Sexton, Ernst & Young Qatar
Venue: Conrad Istanbul Hotel
Room: M-30 Meeting Room
Issues and challenges faced in the region and finding possible solutions:
·  Taxation of oil and gas service companies
·  Taxation leisure and tourism related services
·  Taxation of construction services
·  Taxation of marketing and distribution services
·  Report on the taxation of services by the UN Committee of Experts on International Cooperation in Tax Matters E/C.18/2010/CRP.7
·  VAT issues in taxation of cross-border services - need to modernize place of supply rules under the VAT / Presenter:
Mr. Reggie Mezu, Director and Tax Leader, The Cragus Group; International Tax Advisor, International Tax and Investment Center (ITIC)
Discussants:
·  Representative from UAE*
·  Representative from Lebanon*
·  Representative from Algeria*
1:15-2:15 PM / LUNCH
SESSION II: Finding Solutions to Fiscal Challenges
Chaired by: Genç Osman YARAŞLI, Deputy Undersecretary, Ministry of Finance, Republic of Turkey
Venue: Conrad Istanbul Hotel
Room: Junior Ballroom
2:15-3:30 PM / Policy Options for Countries in the Region:
·  Shift of taxation to consumption, including introduction of excises in GCC countries.
Drivers:
o  need to diversity revenues away from reliance on resource revenues;
o  impact of trade agreements.
·  Encouraging growth of new industries – tourism, financial services.
o  impact of OECD’s harmful tax competition project on tax incentives for financial sector
·  Broadening the income tax base
·  Enhancing the investment climate
o  role of tax incentives generally / Presenter:
Professor Lee Burns, University of Sydney
Discussants:
·  Ms. Awatif Al Hakmani, Director General of Investigation & Assessment, Ministry of Finance, the Secretariat General for Taxation, Oman*
·  Representative from Tunisia*
·  Mr. Erdal Calikoglu, E&Y Turkey
3:30 PM-4:00 PM / TEA AND COFFEE BREAK
4:00-5:30 PM / SESSION II: Finding Solutions to Fiscal Challenges - CONT.
Chaired by: Mr. Daniell A. WİTT
Tax Administration:Design and Administration of Comprehensive CompliancePolicies
·  Towards more effective tax compliance and audit policies and techniques.
·  Best practices in tax administration from European experience,
·  The need for transparency.
·  Important first steps in modernization of a tax administration.
·  How can easier compliance for taxpayers improve performance of tax administration? / Presenter:
Mr. Marek Welenczyk, Executive Secretary, Intra-European Organisation of Tax Administrations
Discussants:
·  Mr. Robert Kelly. Tax Manager, Qatar Financial Centre Authority (QFCA)
·  Mr. Mohamad Saeed El-Haj, Assistant Deputy for Information and Tax Compliance, Tax Authority, Yemen
·  Mr.Yıldırım BOZBIYIK, Head of Group, Turkish Revenue Administration
7:30-9:30 PM / WELCOME DINNER
Hosted by the Ministry of Finance, Republic of Turkey
SESSION III: Important Tax Technical Issues for the MENA Region
9:00-10:30 AM / Breakout Session 3: Taxation of Islamic Finance Transactions
Chaired by: Mr. Ian Anderson, CFO and Tax Director, QFCA
Venue: Conrad Istanbul Hotel
Room: Junior Ballroom
·  International tax issues arising from in Islamic Finance transactions
·  Improving understanding of Islamic Finance to treaty partners which do not have such a sector
·  Need for a commonly agreed analysis of certain transactions.
·  Launch of a major regional study and request to regional countries to participate. / Presenter:
Mr. Mohammed Amin, FCA
Discussants:
·  Mr. Salah Gueydi*
·  Representative from the financial/banking sector*
·  Representative from Egypt*
11:00AM-12:30 PM / Breakout Session 4: International Taxation of large corporate groups: Transfer Pricing Rules and experience from European countries.
Chaired by: Mr. Reggie Mezu
Venue: Conrad Istanbul Hotel
Room: M-30 Meeting Room
·  A workable transfer pricing regime in the region:
o  Regional experience with different methodologies
o  Comparison of traditional methods with profit based methodologies
o  Finding comparable data in sectors important to the region
o  Creating a Database Appropriate to the Region
·  Group taxation issues and recent European developments – insights for MENA countries. / Presenter:
Mr. Chris Lenon, Senior Advisor, ITIC, and
Group Strategic Adviser, Tax Policy, Rio Tinto
Discussants:
·  Mr. Ali ÇİÇEN, Head of Department, MoF, DG of Revenue Policies
·  Mr. Clarence Ellis, Schlumberger
·  Mr. Sridhar Sridharan, E&Y Oman
10:30-11:00 AM / TEA AND COFFEE BREAK
11:00AM-12:30 PM / Breakout Session 5: Issues in Taxation of Natural Resource Companies
Chaired by: Mr. Daniel A. Witt
Venue: Conrad Istanbul Hotel
Room: Junior Ballroom
·  Resource rent tax
·  Participation of IOCs as a contractor to NOC
·  Hypothecation of resource revenues for sovereign funds for oil and gas wealth
·  Balancing revenue needs for governments with incentives to promote investment in a vibrant resource sector. / Presenter:
Mr. Ali Samara, Ernst & Young, Iraq and Jordan*
Discussants:
·  Representative from Iraq*
·  Representative from an International Oil Company*
·  Representative from Saudi Arabia
11:00AM-12:30 PM / Breakout Session 4: Tax Treatment of branches and liaison offices in the region: Treaty Issues and PE’s.
Chaired by: Mr. Hafiz Choudhury
Venue: Conrad Istanbul Hotel
Room: M-30 Meeting Room
·  Importance of PE rules for source country taxation of business profits
·  Defining PE in tax treaties – OECD vs. UN Model Treaties
·  Allocation of profits to a PE
·  Services PEs in the 2008 OECD Model Convention
·  Functions, assets and risks in a PE context – new OECD approach / Presenter:
Mr. Thomas Hanzely, Managing Director, BBD Enterprises
Discussants:
·  Professor Lee Burns
·  Representative from OECD
·  Representative from corporate taxpayer with service PEs
12:30-1:30 PM / LUNCH
SESSION IV: Taxation and Economic Growth – Challenges for the Future and Forthcoming Developments in the Region
Moderator: Mr. İsa COŞKUN, Deputy Undersecretary, Ministry of Finance, Republic of Turkey
Venue: Conrad Istanbul Hotel
Room: Junior Ballroom
1:30 – 2:45 PM / Panel Discussion: Building a wider revenue base for countries in the MENA region. As countries in the region expand and diversify their economies, what challenges do they face and what policy choices are there for them to deal with such challenges / Discussants:
·  Mr.Niyazi ÖZPEHRİZ, Head of Department, MoF, DG of Revenue Policies
·  Representative from Saudi Arabia*
·  Representative from Iraq*
·  Representative from Algeria*
·  Representative from Egypt*
2:45-3:15 PM / TEA AND COFFEE BREAK
3:15-4:45 PM / Application and Implementation of VAT in the Region:
Chaired by: Mr. Seyit Ahmet BAŞ, Deputy Undersecretary, Ministry of Finance, Republic of Turkey
·  Introducing a VAT in the GCC – status and concerns.
o  key design issues in VAT:
o  cross border services, financial supplies, telecommunications services, tourism sector, immovable property, and importance of limiting exemptions
o  interaction with excisable goods
o  lessons from other jurisdictions
·  Experience in VAT in MENA countries – measuring the VAT gap.
·  Comparative experience from Europe / Presenter:
Professor Lee Burns
Discussants:
·  Mr. Job Kabochi, GE
·  GCC - Secretariat General*-TBC
·  Mr. Saleh Yousef M J Al Mullah, Head of Public Revenue and Taxes Policy Section , Ministry of Economy and Finance, State of Qatar
4:45-5:30 PM / Closing Plenary Session
Chaired by: Mr. Ünal TAYYAN, Director General, Directorate General of Revenue Policies, Ministry of Finance, Republic of Turkey / Speakers:
·  Mr. Ali ÇİÇEN, Head of Department, MoF, DG of Revenue Policies
·  Mr. Daniel A. Witt
·  Mr. Salah Gueydi
·  Mr. Hafiz Choudhury
5:30 PM / FORUM ADJOURNED
Evening / DINNER
Hosted by the International Tax and Investment Center

* Proposed