Global tax points for insurers. Volume 2 Issue 2

Transcription

1 Global tax points for insurers Volume 2 Issue 2

2 Foreword Welcome to our latest issue of Global tax points for insurers, an informal series that provides insurance executives with a snapshot of some of the interesting developments in the ever-changing world of tax around the globe. In this issue, we look at a number of developments in tax for insurance companies. We begin by looking at the border adjustment set out in the US House Republican leaders comprehensive tax reform package. At this stage, we do not know whether the proposals will impact insurers but, if they do, we examine some of the key questions that will have to be resolved. Next, we move across the border to Mexico, where we pick up on the Mexican tax administration s initiative to digitize its relationship with taxpayers. This is an ambitious project that is putting real pressure on insurance companies to transform their tax reporting systems and, in some cases, to seek judicial relief from the effects of the new rules. After much deliberation, the International Accounting Standards Board (IASB) has now released the final text of International Financial Reporting Standards (IFRS) 17, dealing with accounting for insurance contracts. We discuss the implications of the new standard through an Asia-Pacific lens, where many of the tax authorities have yet to come to grips with its potential impact on the tax liabilities of insurance companies in their countries. Next, we move down to New Zealand, where a package of base erosion and profit sharing (BEPS) related tax reforms have been announced. Of particular interest to insurers will be the proposed rules on thin capitalization and debt caps. We then move up to Japan, where there is a developing focus on insurance premium tax (IPT) risks among the Japanese-headquartered multinational insurers as they expand their business in Europe and elsewhere. It is becoming apparent that the complexity of the multicountry policies they are now writing combined with the pressure from insureds to understand their tax cost is demanding a greater analysis of the IPT liabilities that arise. Finally, we look at Europe and a project by the European Commission to design a Pan-European personal pension product. The diversity of the tax and regulatory rules governing pension products in the various Member States, together with social and welfare considerations, means that harmonization is an ambitious goal and the project remains a work in progress. We hope these articles will help you navigate the evolving tax environment, and we look forward to sharing our tax insights with you through this series. Hugh von Bergen EY Global Insurance Tax Leader

3 Table of contents US tax reform border adjustability proposals and their potential impact on insurers 2 Digitization of tax filings in Mexico 4 IFRS 17: what does this mean for tax in the Asia-Pacific region? 6 Proposed legislative amendments impacting insurers in New Zealand 8 Insurance premium tax (IPT) considerations for Japanese multinational insurers 10 Exploring the feasibility of a Pan-European personal pensions product 12 Global tax points for insurers: Volume 2 I Issue 2 1

4 US tax reform border adjustability proposals and their potential impact on insurers Prospects for comprehensive US tax reform in 2017 or early 2018 are real. The process of designing tax reform began last June when US House Republican leaders released a proposal outlining comprehensive tax reform (the Blueprint). 1 The Blueprint proposes to reduce US corporate income tax rates from the current rate of 35% to a rate as low as 20%. To offset tax rate reductions, the Blueprint raises significant revenue, in part by implementing a border tax adjustment mechanism in which, generally, revenues from exports are not subject to corporate income tax, while revenues relating to imports are subject to tax. 2 The specifics of the border tax adjustment mechanism are yet to be determined, and it is unclear whether border tax adjustments will ultimately be included as a part of US tax reform. However, it is important to understand the potential ways in which border tax adjustments may impact insurance companies. From a US manufacturer s perspective, border adjustments are relatively easily understood: gross revenue generated from exports is not taxed, while their domestic costs of goods sold would be deductible. On the import side, revenues from selling imported goods or products manufactured with imported goods are taxed, while costs associated with imports are not deductible. In contrast, the manner in which cross-border financial transactions, including insurance or reinsurance contracts, would be treated under a border adjustability regime is unclear. There are two macro-level questions facing the insurance industry: 1. Will cross-border insurance transactions be subject to border adjustments (i.e., is insurance a service or a financial instrument)? 2. Is an outbound insurance transaction considered an import or an export, and conversely, is an inbound insurance/reinsurance transaction an import or export? Is insurance a service or financial instrument? If insurance is deemed to be providing a service, it is likely to be included in the border adjustment regime. Conversely, if insurance is considered a financial instrument, it may be exempt from border adjustments. The decision will ultimately need to be made by legislators, as there is no guidance from the current US tax authorities addressing the issue. 1 This document was published by the House of Representatives Republican Tax Reform Task Force on 24 June 2016, under the title A Better Way Our Vision for a Confident America and can be found at 2 For more on the Blueprint s border adjustability proposals, see the EY Tax Alert, US tax reform what you need to know about border adjustments, November 22, 2016, 2

5 Import view The import view is that the foreign insurer is providing the US cedant a service and that service is being imported. If this view prevails, the reinsurance premium paid to the offshore reinsurer may be disallowed, as costs associated with imports are not deductible under the House border adjustment mechanism. Whether the outbound premium paid can be netted against the ceding commission in determining taxable income is unclear. If an outbound transaction is an import, then an inbound transaction is an export, and the House border adjustment mechanism favors exports. Thus, the inbound premium received by the US insurance company may not be taxable. Again, it is unclear whether the ceding commission would be netted against the non-taxable premium or if it would generate a current tax deduction. Export view The export view, in an outbound transaction, is that the insurance risk is being exported offshore, or shifted/ transferred to a foreign country. The result is an inverse treatment of reinsurance transactions compared to the import view. This view is favorable toward outbound reinsurance transactions and detrimental for inbound transactions. Some Trump administration officials and certain members of Congress have expressed concerns with border adjustability. In April 2017, the Trump administration released a very high-level outline of a plan that did not include border adjustability. Ambitious tax rate reduction combined with broadening the tax base is the common objective of all US tax reform proposals, but the devil is in the details, and those details remain fluid. Legislation will certainly evolve through compromise as it moves through the US legislative process. Companies that understand the concepts behind the tax reform proposals, including border adjustability, and that engage with policymakers now will be better positioned as legislation is developed. Norman J. Hannawa Principal International Tax Services Ernst & Young United States Ann B. Cammack Principal National Tax Services Ernst & Young United States John C. Owsley Manager International Tax Services Ernst & Young United States Global tax points for insurers: Volume 3 I Issue 1 3

6 Digitization of tax filings in Mexico The digital age is transforming the relationship between tax authorities and taxpayers. As tax authorities seek increased revenue due to budgetary deficits and face shrinking resources to deal with compliance, they are relying on digital platforms to facilitate real-time access to data, revenue collection and taxpayer assessments. Mexico is taking a leading-edge approach to digitization of tax filings and data submissions from taxpayers. 3 In July 2014, the Mexican Tax Authority (SAT) issued requirements for electronic accounting information that are in line with the new rules of the latest Mexican tax reform. The obligation for taxpayers to keep records and entries through digital or electronic documents and to upload such information on the SAT website is mandatory. Which information should be filed? Chart of account (accounts groupings) Regulated entities Mínimum catalogue CNBV (Report R01) Non-regulated entities Grouping Code Annex 24 Months Deadline January, February, March May 3 April, May, June August 3 Trial balance July, August, September November 3 October, November, December Adjusted Trial Balance March 3 April 20 of the following month Journal entries, accounting records Type of report Tax sheet (folio) General ledger Sub-accounts first level Send assumptions SAT requirements offsettings Tax refund request 3 In July 2014, the SAT published the second amendment to the Miscellaneous Tax Resolution, which lists requirements for electronic accounting information in line with the new rules in the latest Mexican tax reform. The amendment introduced an obligation for taxpayers to keep digital records and upload them on the SAT website, observing general SAT provisions. 4

7 In addition, the SAT requires 100% compliance in maintaining and transmitting tax data and transactional information in electronic format. It has the authority to use information from treaty member countries and other governmental agencies to perform real-time analysis to monitor tax filings, manage payments and refunds, and implement analytical tests to issue electronic audits (e-audits) and assessments. This includes data analytics and data matching to target compliance and audit initiatives. In view of this new rule, several taxpayers opted to file an injunction in 2014 against the constitutionality of this tax obligation since taxpayers require additional time to prepare their IT architecture and reporting infrastructure. For those that filed an injunction, they have until the end of October 2017 to receive a response from the judicial authorities to submit the accounting information. The effective periods for filing will appear in the injunction response; however, taxpayers must be ready to upload information digitally when the ruling is received. The level of transactional detail that needs to be reported is granular, as illustrated above. In addition to the chart of accounts and trial balance, in certain cases it also would be mandatory to upload journal entries, accounting records at subaccount levels, detailed information of accounting policies generated per transaction, accounting papers and supporting documentation such as invoices and contracts. Each accounting policy clearly should indicate the digital invoice supporting the transaction and identify applicable tax rates and activities for which no tax is paid. Tax identification numbers for transactions with third parties will also be shared with SAT. As part of the 2014 tax reform, SAT is authorized to perform electronic tax audits on taxpayers, joint liable parties and related third parties, based on analysis of information and documentation provided by taxpayers. A taxpayer typically has 15 days from the date of audit notice to provide information requested and challenge the tax assessment. If the taxpayer complies, tax authorities have 40 days to issue a final decision and notify the taxpayer. If the taxpayer does not provide information within the 15-day period, the preliminary tax assessment becomes final, and tax authorities may assess tax through an administrative legal execution procedure. Insurers face challenges and increased costs to comply with the SAT s digital reporting. Taxpayers should assess whether their tax function is optimal to meet the digital data and filing obligations and be prepared to defend audits in real time. Implementation of digital solutions and the use of real-time data analytics for tax (to measure and mitigate risk and controversy before it occurs) may help to avoid more costly remedies in the future. Pablo Wejcman Executive Director International Tax Services Ernst & Young United States Alejandro Rodriguez Diego Senior Manager Global Compliance and Reporting Ernst & Young Mexico Global tax points for insurers: Volume 3 I Issue 1 5

8 IFRS 17: what does this mean for tax in the Asia Pacific region? On 19 May 2017, the International Accounting Standards Board issued a new insurance contracts standard International Financial Reporting Standard 17. Insurers are required to fully implement this standard by 1 January 2021, triggering a significant change in the way insurers measure and recognize profit, and their presentation and disclosure of insurance contracts. The standard adopts different models to measure the future cash flow, liabilities and earnings for long-term, short-term and direct participating insurance contracts. These models are fundamentally different from the current accounting practice of many insurers in the Asia-Pacific region. The change will not only give rise to significant financial reporting implications, but will also operationally impact insurers by adding complexity to the valuation process and imposing substantial additional requirements. Whilst many insurers have already started the process of understanding and assessing the technical requirements of IFRS 17, less focus has been given to understanding how the standard might impact the insurer directly or indirectly from a tax perspective. The types of tax issues that need to be considered include: Whether the changes will alter the insurer s taxable profit. This will depend on factors such as the way that an insurer is taxed in a particular country. For example, in countries where tax is based on a percentage of premiums received, changes in the accounting recognition of profit may be less relevant than in countries where insurers are taxed on accounting profit and reserve movements. Classifying certain contracts as short-term. Certain short-term contracts (e.g., yearly renewable term contracts) may be dealt with by the proposed premium allocation approach. This could mean that acquisition costs may need to be recognized over a shorter period, resulting in changes to tax payable and deferred taxes in some countries. Potential tax policy or legislation changes. This could include, for example, whether an increase in profit transparency and disclosure together with a pattern more reflective of the period of risk could ignite debate around tax change. The industry and individual insurers should consider their role in the context of this debate. Treatment of legacy products. Insurers will be considering their legacy book as part of the implementation process. To the extent that products may be closed down or realigned, taxation will need close consideration in the context of both the insurer and the insured. Tax governance and transparency. Tax governance and transparency are becoming increasingly important around the region. Changes to accounting profit may impact effective tax rates and necessitate explanations to stakeholders. Insurers should understand and articulate the potential impact of tax transparency requirements and governance expectations. Whether the changes will impact deferred taxes. In some countries, deferred taxes may be impacted by the application of IFRS 17. It will be necessary to understand how it may be impacted and whether a change might affect other areas such as capital requirements. 6

9 Most tax authorities across the region have not released any opinions and clarifications associated with the standard to date. Assessing the potential tax implications will not be easy under current tax laws and practices until there is further clarity from the regulators on the impact of IFRS changes on the local statutory financials (starting basis for tax return computation). It is important to communicate early with stakeholders about the potential tax impact and any volatility in the taxable income and effective tax rates brought by the change. Therefore, it would be in the interest of insurers to engage with the tax authorities on a regional coordinated basis (e.g., coalition efforts) in the jurisdictions where they operate to gain a higher degree of certainty on the road to transition. Regulators and taxing authorities are also coming to grips with the proposed changes, and they would welcome such discussions with the insurance operators. Helen Mok Senior Manager Business Tax Advisory EY Asia-Pacific Financial Services Ernst & Young Hong Kong Dale Judd Tax Partner Business Tax Advisory EY Asia-Pacific Financial Services Ernst & Young Australia Global tax points for insurers: Volume 3 I Issue 1 7

10 Proposed legislative amendments impacting insurers in New Zealand Recently released legislative proposals are aimed at strengthening New Zealand s rules for taxing large multinational companies. The proposals outlined below will impact the insurance sector and, we expect, will result in an increase in disputes between taxpayers and the taxing authority (Inland Revenue). Legislative proposals are aiming to tighten the thin capitalization rules by limiting the interest rate that can be applied to related-party loans from a nonresident New Zealand borrower and excluding certain non-debt liabilities from the thin capitalization asset base. While the proposals are aimed at a minority of multinationals that are borrowing from foreign affiliates at high interest rates, leading to excessive interest deductions in New Zealand, the scope of the proposals is very broad. In general, these changes will mean: Recalculating debt to asset ratios to effectively allow for a reduced level of debt relative to assets Repricing existing loans, which will increase compliance costs and lead to disputes through negotiations with foreign lenders who may be unwilling to accept lower interest rates Although most multinationals take conservative debt positions, with moderate debt-to-asset ratios, these changes will need to be addressed. This could lead to a risk of double taxation with overseas tax administrations demanding a higher return. 4 In addition, companies will no longer be able to calculate their thin capitalization position at year-end. Instead, either quarterly or daily calculations will be required, which has the potential to significantly increase compliance costs. 4 New Zealand has a network of 40 Double Tax Agreements in force with its main trading and investment partners. 8

11 Interest rate cap The Government intends to cap the deductible interest rate on related-party loans, based on the interest rate the ultimate parent can borrow at. The cap will take account of the yield derived from so-called appropriate senior unsecured corporate bonds at the parent level, plus a margin. For taxpayers whose principal of all cross border-related party loans is more than NZ$10 million, additional pricing factors will need to be considered when determining an appropriate interest rate on relatedparty loans. In developing these proposals, Inland Revenue appears to have underplayed the commercial reality of related-party cross-border loans and not to have considered the impact on highly regulated entities, such as insurers where the majority of the group debt has appropriate regulatory recognition and is heavily subordinated for a long term. Exclusion of non-debt liabilities Current thin capitalization rules give foreign-owned companies a safe harbor, 5 allowing tax deductions for interest payments on debt up to 60% of their New Zealand asset value. The government proposes to restrict allowable assets by excluding non-debt liabilities such as trade credits, employee provisions, tax liabilities, impairment and other provisions, as well as industry-specific liabilities such as policyholder liabilities, outstanding claims reserves and certain interest-free loans. This inherently will impact the insurance sector significantly, as safe harbor provisions will be limited. Implications for New Zealand Inbound Insurers In summary, the proposals in their current form will lead to increases in the tax base, the potential disputes with authorities and compliance costs across tax and financial reporting. Insurers should take the opportunity to assess the shape of their supply chain and financing arrangements before the proposals are passed into law. This will help realign an insurer s tax governance framework model to ensure that there is a structured approach to managing the tax function. This, in turn, will help the resolution process and provide better communication with stakeholders. Matthew Hanley Tax Partner Business Tax Advisory Ernst & Young New Zealand Gary Burr Senior Manager Business Tax Advisory Ernst & Young New Zealand Hayden Vickers Tax Consultant Business Tax Advisory Ernst & Young New Zealand 5 Under current New Zealand tax law, a deduction is generally allowed for interest expenditure to the extent interest-bearing liabilities do not exceed 60% of total assets. Global tax points for insurers: Volume 3 I Issue 1 9

12 Insurance premium tax (IPT) considerations for Japanese multinational insurers Historically, Japanese multinational insurers have been underwriting risks for their customers, many of which are top multinational groups operating in Europe for decades. In addition, Japanese insurers are continuing to seek expansion into Europe to invest excess capital due to the low growth and interest rate environment in Japan. As multinational companies focus on managing their subsidiaries, they are facing new risks and potential compliance issues related to insurance premium tax (IPT). As a result, multinational insurance programs that provide centralized control over risk management are expected to increase. The business purpose of a multinational insurance program is to offer risk coverage from the home country (i.e., Japan) and thus minimize insurance costs. The use of non-admitted insurance in a multinational program presents a cost-effective way to provide local coverage whereby a policy issued in the parent country covers exposures in other countries where subsidiaries are located. For decades, this has been the norm for Japanese insurers underwriting risks on behalf of customers operating in Europe. Another consideration for Japanese multinational groups operating overseas is when a company purchases insurance to protect capital it has invested in an overseas subsidiary for a loss resulting from a political act such as nationalization. The risk does not attach to the overseas subsidiary but to the investment made by the company; the premium in practice is taxable in the country where the parent company is based. However, when property or people are covered, the argument loses some ground, particularly in Europe after the Kvaerner ECJ case 6 and when claim payments are made directly to individual countries. With a global trend for governments to shift from direct to indirect taxation, an increasing number of countries in Europe have introduced or increased IPT. This has led to increased audits and rate increases, widening the scope for insurance activities that fall under IPT reporting. Multinational insurers operating in Europe need to manage the reputational and financial risk of IPT compliance on behalf of themselves and their customers. Japanese insurers writing coverage from their country for customers operating in Europe have to consider IPT implications closely. In practice, usually the brokers and insurers are responsible for calculating and settling IPT at a local level. However, if the insurer does not have a license in a country, IPT may still be applicable and depending on the country has to the settled by the policyholder or the insurer. This can trigger a compliance cost and reporting requirements. 6 ECJ: C-191/99 Kvaerner plc v Staatssecretaris van Financiën The case ruled that the insured parent company is obliged to pay premium tax on part of its global professional liability insurance program that covered a subsidiary in the Netherlands. The case was instrumental in enabling tax authorities to collect IPT from nonresident insurers and clarified the location of risk rules used in Europe. 10

13 In the case of life insurance, 10 countries in Europe charge IPT or similar charges on insurance premiums, including Austria, Belgium, Greece and Portugal. Following the RVS ECJ case 7, IPT is payable where the policyholder resides after moving to a new country. Due to the implementation of Common Reporting Standards in Japan 8, tax authorities could recognize the tax residency of the policyholders. If a policyholder moves to the above mentioned countries, the policyholder may be obligated to pay IPT. Given the growing significance of IPT due to continuous rate increases and policyholder audits, insurers and multinationals need to work together to mitigate IPT risks. Japanese insurers who have operated in Europe for decades should consider an in-depth review of their insurance program, premium apportionment methodology and assess risk of non-compliance and reputational risks as the obligation may pass on to the policyholders unbeknownst to them (customers of the insurer). Proactive oversight of tax rate increases and scope of IPT (which varies by jurisdiction), using a consistent and pragmatic premium apportionment methodology as well as establishing a robust compliance process would be suggested solutions to consider. Midori Otomo Executive Director Global Compliance & Reporting Ernst & Young Japan Tax Tom Hilverkus Senior Manager Indirect Tax Ernst & Young United Kingdom 7 ECJ: C-243/11 RVS Levensverzekeringen NV v Belgische Staat In this case, a Dutch policyholder moved to Belgium, where in contrast to the Netherlands IPT is charged on Life insurance. The court ruled that when establishing the risk location for life/personal insurance, a dynamic approach should be taken, i.e., IPT is charged where the policyholder resides (Belgium) and not where they have taken out the policy (Netherlands). 8 Standard for Automatic Exchange of Financial Account Information developed in the context of the Organisation for Economic Co-operation and Development (OECD). In Japan, Common Reporting Standards will be effective 1 January 2017, and the first report is to be submitted by the reporting financial institutions by 30 April Global tax points for insurers: Volume 3 I Issue 1 11

14 Exploring the feasibility of a Pan-European personal pensions product All European Union (EU) Member States are faced with an aging population, challenges of pension sustainability and adequacy of pension regimes. In a challenging economic environment with low rates and expectations of the evolution within the framework of public pension schemes (Pillar 1), 9 occupational (Pillar 2), 10 and voluntary privately funded accounts (Pillar 3), there appears to be a deficit gap. Given these challenges, the European Commission has launched a study with EY on the feasibility of the framework for a Pan-European personal pension (PEPP) product. In the context of the capital market union action11 plan, the European Commission has stressed the need to encourage the development of voluntary pension savings with a long-term investment strategy and retirement objective. The EU private pension savings market varies greatly, particularly with regard to the level of maturity of national markets that offer alternative consumer solutions. Capital market sophistication, cultural bias, generous pension systems and level of wealth may hinder the development of the pension scheme within national borders. Within this context, there is discussion to encourage pension savings through the development of cross-border activities and portability of pension products on a Pan-European basis. A PEPP product is a private pension product designed at the EU level and then marketed by European institutions. Implementation of such a product on a pan-regional basis has legal, regulatory and tax considerations within the EU. The legal and regulatory frameworks are not fully harmonized at the European level, creating a major obstacle to a fluid EU private pension market. Notably, conditions to access the Pillar 3 products and the legal retirement age, which directly impacts the architecture of a given PEPP, vary across the EU. In particular, national tax regimes are very diverse, though some major trends could be highlighted; notably in a majority of Member States, in-payments are encouraged through tax relief and outpayments are taxed. 9 State Pension Provided by Government 10 Occupational pension stemming from the employer and employee relationships (Pillar 2) 11 The capital markets union is a plan of the European Commission to build a true single market for capital in the EU by The European Commission has started working with EU countries to examine national barriers to the free movement of capital. 12

15 The variety of conditions to benefit from tax incentives could be considered as the main issue for achieving a harmonized EU personal pension market and designing a Pan-European product that should be easily adapted by providers to national environment. A simple adaptation of the product to local regulations should allow policyholders the flexibility to change their tax residency within the EU, to obtain national tax incentives linked to private pension products and encourage providers to develop cross-border activities in less developed or mature pension markets. In addition, another challenge to consider is the impact on regulatory and supervision rules of a production and distribution of the product opened to different types of providers. In summary, the launching of a Pan European product is envisaged by the European Commission since this option could correspond to a first step in terms of harmonization of the market, which will provide liquidity and development of the capital markets and from a fiscal policy standpoint encourage pension growth for an aging population. It would be worthwhile for pension providers and related stakeholders to develop a strong expertise and knowledge around the local rules, markets and legislation dealing with retirement schemes across Europe and engage with tax authorities to harmonize tax considerations. This will create an efficient and competitive pension scheme, reducing barriers to the provision of pension services across borders and increasing competition between pension providers. Vincent Natier Tax Partner Financial Services Ernst & Young Société d Avocats Franck Chevalier Partner Advisory Financial Services Ernst & Young Advisory Global tax points for insurers: Volume 2 I Issue 2 13

16 EY contacts Hugh von Bergen Global Insurance Tax Leader Norman J. Hannawa Principal, International Tax Services Ernst & Young LLP United States Ann B. Cammack Principal, National Tax Ernst & Young LLP United States John C. Owsley Manager, International Tax Services Ernst & Young LLP United States Pablo Wejcman Executive Director, International Tax Services Ernst & Young LLP United States Alejandro Rodriguez Diego Senior Manager, Global Compliance and Reporting Ernst & Young LLP Mexico Helen Mok Senior Manager Business Tax Advisory EY Asia Pacific Financial Services Ernst & Young Hong Kong Dale Judd Tax Partner Business Tax Advisory EY Asia-Pacific Financial Services Ernst & Young Australia Matthew Hanley Tax Partner, Business Tax Advisory Ernst & Young New Zealand matthew.hanley@nz.ey.com Gary Burr Senior Manager, Business Tax Advisory Ernst & Young New Zealand gary.burr@nz.ey.com Hayden Vickers Tax Consultant Business Tax Advisory Ernst & Young New Zealand hayden.vickers@nz.ey.com Midori Otomo Executive Director, Global Compliance and Reporting Ernst & Young Japan Tax midori.otomo@jp.ey.com Tom Hilverkus Senior Manager Indirect Tax Ernst & Young United Kingdom thilverkus@uk.ey.com Vincent Natier Tax Partner Financial Services Ernst & Young Société d Avocats vincent.natier@ey-avocats.com Franck Chevalier Advisory Partner Financial Services Ernst & Young Advisory franck.chevalier@fr.ey.com EY Assurance Tax Transactions Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com EYGM Limited. All Rights Reserved. EYG no: Gbl BD ED None This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax or other professional advice. Please refer to your advisors for specific advice. ey.com