European Fiscal Services

European Fiscal Services

 Highlights of the millennium years  Current Drivers  The Next 2 years  Tax Practice of the future  Discussion points October 2013 European Fiscal Services Ltd 3

 Client Relations  Software developments › Professional › State sponsored  Old methods new problems  Pressure on fees October 2013 European Fiscal Services Ltd 4

 Anti Money laundering  Regulation and Competition  Tax Avoidance/Abuse › Ethics › Client expectation › State reaction  The need to invest October 2013 European Fiscal Services Ltd 5

 ECONOMIC CRASH October 2013 European Fiscal Services Ltd 6

 G8 to G20  Revenue Authorities  OECD  Tax Activists and NFPs  Highly visible corporate planning  The Politics of tax havens October 2013 European Fiscal Services Ltd 7

 BEPS › Base Erosion and Profit Shifting  OECD Global Tax Forum › Automatic exchange of information  OECD 15 point plan › G20 plus 16 committed to reform of global taxation model October 2013 European Fiscal Services Ltd 8

› The search for  Transparency  Consistency  Certainty › Tax “fairness” October 2013 European Fiscal Services Ltd 9

 The Digital Economy  Prevent Treaty Abuse  Neutralise hybrid mismatch arrangements  Prevent the artificial avoidance of P.E. Status  Re-examine transfer pricing documentation October 2013 European Fiscal Services Ltd 10

 Counter harmful tax practices transparency and substance  Transfer pricing outcomes in line with intangible value creation  Develop a multilateral instrument October 2013 European Fiscal Services Ltd 11

 Strengthen CFC rules  Limit base erosion by interest and other financial payments  Transfer pricing outcomes in line with risk and capital value creation  Transfer pricing outcomes in line with other high risk transaction value creation  Methods to collect and analyse BEPS data – actions to address  Disclosure of aggressive tax planning by taxpayers  Effective dispute resolution mechanisms October 2013 European Fiscal Services Ltd 12

Automatic bilateral exchange of information October 2013 European Fiscal Services Ltd 13

 Compliance  Risk management › Client › Authority › Staff  Tax in a changing environment October 2013 European Fiscal Services Ltd 14

 Training  Software  Practice assured October 2013 European Fiscal Services Ltd 15

 Tax Planning for clients  Avoidance issues  The Australian Experience  What registration really means  Client/Revenue/Arbitrator? October 2013 European Fiscal Services Ltd 16

 Forensic  Recovery  Restoration  Support through litigation  Untying the knots  Cross border transactions  New Taxes October 2013 European Fiscal Services Ltd 17

 Risks involved  Where does the profit come from  Relations with clients  Relations with revenue  Regulation, Registration or laissez faire October 2013 European Fiscal Services Ltd 18

Thank you! Food for thought? October 2013 European Fiscal Services Ltd 19