1. Jiri Nekovar President of CFE Global pressure in taxation policy

2. Global efforts to recover taxes The exchange of information between tax administrations – 119 countries – activity of OECD Anti-money laundering act – activity of OECD Base Erosion and Profit Shifting – activity of OECD / G-20 Aggressive tax planning – activity of EU Taxation of savings – activity of EU FATCA – activity of the U.S.A. with a global impact Inconsistency in definitions of intangible assets between UN and OECD in relation to “transfer pricing” and new activities of BRIC GhanaGlobal pressure in taxation policy February 2014Jiri Nekovar 2

3. BEPS – Action plan of OECD Action 1 - Address the Tax Challenges of the Digital Economy Action 2 - Neutralise the Effects of Hybrid Mismatch Arrangements Action 3 - Strengthen CFC Rules Action 4 - Limit Base Erosion via Interest Deductions and Other Financial Payments Action 5 - Counter Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance Action 6 - Prevent Treaty Abuse Action 7 - Prevent the Artificial Avoidance of PE Status Action 8 - Assure that Transfer Pricing Outcomes are in Line With Value Creation/ Intangibles Action 9 - Assure that Transfer Pricing Outcomes are in Line With Value Creation/ Risks and Capital Action 10 - Assure that Transfer Pricing Outcomes are in Line With Value Creation/ Other High- Risk Transactions Action 11- Establish Methodologi es to Collect and Analyze Data on BEPS and the Actions to Address It Action 12 - Require Taxpayers to Disclose Their Aggressive Tax Planning Arrangement s Action 13 – Re-examine Transfer Pricing Documentation Action 14 - Make Dispute Resolution Mechanisms More Effective Action 15 Develop a Multilatera l Instrument GhanaGlobal pressure in taxation policy February 2014Jiri Nekovar 3

4. BEPS – Foreign direct investment 2010: 5.11 % of global foreign direct investment (FDI) points to Barbados, Bermuda and the British Virgin Islands (Germany 4.77 %, Japan 3.76 %) The British Virgin Islands is the second largest investor to China, where it brought 14 % of all FDI (Hong Kong 45 %, USA 4 %) The largest foreign direct investors to Russia – Cyprus (28 %), British Virgin Islands, Bermuda and Bahamas GhanaGlobal pressure in taxation policy February 2014Jiri Nekovar 4

5. Countries struggle to attract foreign investment Foreign investment as of the end of 2012 in the Netherlands and Luxembourg amounted to USD 5.8 tn - More than in the U.S.A., UK and Germany in total.  According to OECD, the Netherlands accumulated foreign investment amounting to USD 3.5 tn, but only USD 573 bn ended in the “genuine” Dutch economy.  The G–8 and G-20 countries have put taxes on the first place in their agendas.  Starbucks, Amazon, Google in the United Kingdom and Apple in the U.S.A. pay little in taxes by the parliamentary committee. https://docs.google.com/file/d/0B2ps1bX4Rc0zdkZlQlVMQzY4VW8/edit?usp=sharing GhanaGlobal pressure in taxation policy February 2014Jiri Nekovar 5

6. G-20 vs. OECD G-20 85 % of global GDP Over 75 % of global trade 2/3 of world population OECD 65 % of global GDP About 63 % of global trade 20 % of world population GhanaGlobal pressure in taxation policy February 2014Jiri Nekovar 6

7. G-20 Countries of OECDNon-OECD countries Country GDP per capita (USD) Share in the world trade (% GDP) Country GDP per capita (USD) Share in the world trade (% GDP) South Korea30,80056.5Saudi Arabia31,80056.2 Germany41,23151.8Russia22,40829.4 Mexico18,28833.0South Africa10,79828.3 United Kingdom 37,44631.6Republic of China9,09527.3 Canada41,55930.4Indonesia4,34424.6 Italy33,14030.2India3,90023.8 France36,24927.4Argentina18,40019.7 Turkey18,11426.4Brazil12,10012.6 Australia45,01619.9 Japan35,19014.7 USA51,68913.5 GhanaGlobal pressure in taxation policy February 2014Jiri Nekovar 7

8. G-20 Non-OECD countries Countries of OECD Countries of EU GhanaGlobal pressure in taxation policy February 2014Jiri Nekovar 8

9. St. Petersburg - September 2013 Globalization in taxes – Globalization in tax consultancy G-20 – Base Erosion and Profit Shifting CFE General Assembly with participation of representatives of AOTCA and WAUTI Adoption of the idea of The Global Tax Advisers Co-operation Forum GhanaGlobal pressure in taxation policy February 2014Jiri Nekovar 9

10. www.aotca.org www.wauti.org Confédération Fiscale Européenne 25 countries of Europe www.cfe-eutax.org West African Union of Tax Institutes 15 countries of West Africa Asia Oceania Tax Consultant’s Association 19 countries of the Asia and Oceania Region Self-regulating organizations in the world GhanaGlobal pressure in taxation policy February 2014Jiri Nekovar 10

11. GhanaGlobal pressure in taxation policy February 2014Jiri Nekovar 11 Conclusion  Rights of taxpayers and the Taxpayer Charter model  Result of the CFE – AOCTA – STEP cooperation – participation of 35 countries  Invitation to WAUTI to take part in the Taxpayer Charter project  Paying taxes is not an issue of morality, it is an issue of adherence to high-quality tax legislation  The tax advisers’ task is to help clients to comply with the laws  The role of countries is to create high-quality tax laws and to take part in a rational arrangement of taxation in the world  To send the best tax advisers to workgroups of The Global Tax Advisers Co-operation Forum

12. Thank you for your attention!