Real Estate Deals. Connecting for Good Growth Real Estate Briefing. Lisa McClure PwC CI Real Estate Leader. 20 October 2015
|
|
|
- Erica Thomas
- 5 years ago
- Views:
Transcription
1 Real Estate Deals Connecting for Good Growth Real Estate Briefing 20 October 2015 Lisa McClure PwC CI Real Estate Leader
2 Agenda 1 Presentations Simon Hardwick A view of the markets John Mindham UK tax developments Ben Robins Jersey s perspective 2 Panel discussion 3 Open to the floor 4 Closing comments
3 Connecting for Good Growth A view of the markets Simon Hardwick PwC Legal Partner Emerging Trends in Real Estate Europe & Global Project Chair Independent Non Executive Director: Royal Institution of Chartered Surveyors Management Board Chair: APAM UK commercial property asset Connecting for Good Growth PwC 20 October 2015
4 A View of the Market Emerging Trends in Real Estate 2015 series #emergingtrends
5 Agenda 1 Capital flows Capital allocations to real estate Sources and destinations The Ripple Effect 2 Challenges for Jersey Access to new sources of capital Investors default jurisdiction choices Regulation The tax landscape
6 Capital flows Source: Emerging Trends in Real Estate: The global outlook for 2015
7 Cross border capital into Europe in 2015 Source: Emerging Trends in Real Estate: The global outlook for 2015
8 Capital flows: UK Real Estate Capital Balance forecast 2016 Real Estate Capital Market Balance Forecast 2016 versus 2015 We raised the capital, now what do we do with it? Equity capital for investing % 29 % 64 % % 33 % 55 % Source: U.S. Census Bureau, UDR/Lachman Associates Survey, Gen Y and Housing, Urban Land Institute, November 2014 Source: Emerging Trends in Real Estate Survey
9 Capital flows Investment into Europe Q1 to Q Growth in European investment 20% 157.5bn 3.4bn Growth in Chinese investment 58%
10 Capital flows Top 30 cities for commercial property investment across the world in 2014
11 Europe s 10 most active real estate markets Q1-Q (billons)
12 Investing in Europe: the Ripple Effect The only problem is that we have more money available than product to invest in across Europe. Prime assets are over-priced There is a need to move up the risk curve into secondary markets or assets
13 Challenges for Jersey Investors default jurisdiction choices Regulation Access to new sources of capital The tax landscape
14 Connecting for Good Growth UK tax developments John Mindham, Director, Real Estate Deals Connecting for Good Growth 20 October 2015 PwC
15 Major tax law changes Non-Resident Capital Gains Tax Diverted Profits Tax ( DPT ) Investment or trading? Base Erosion & Profit Shifting ( BEPS )
16 Key questions Commercial or residential? Investment or trading?
17 Non-Resident Capital Gains Tax Applies to capital gains realised by certain non-residents on or after 6 April Capital gains = applies to investment assets, not trading. Applies only to residential property (but with no value de minimis) JPUT No exemptions for trading / rental businesses (unlike Annual Tax on Enveloped Dwellings). Widely held / qualifying institutional investor exemption. Choice re calculation of gain. Heavy compliance burden. Investment asset Residential property Ring-fenced gains and losses.
18 Diverted Profits Tax ( DPT ) UK legislation has been introduced in the Finance Act 2015 which seeks to tax so-called "diverted profits". The rules take effect with regard to trading profits arising on or after 1 April 2015, with tax charged at a rate of 25% on the diverted profits relating to UK activity. There are broadly two provisions / scenarios under which DPT is charged: 1. Insufficient economic substance. 2.Avoidance of a UK taxable preference. New notification, assessment and penalty regime. Pay now, contest later. Exemptions including SMEs, de minimis for UK expenses, exempted loan relationships. Impact on Jersey versus other territories?
19 Diverted profits tax Common UK property development scenarios 1. Insufficient economic substance 2. Avoidance of UK taxable presence Beneficial tax territory / treatment Connection UK contractor, marketing / sales / development manager Overseas UK corporation tax payer Property trade Property interest
20 Diverted profits tax UK property trading developments - key messages Fact specific It s not necessarily all or nothing Engage with DPT sooner rather than later Changing behaviours. Paying corporation tax, not DPT Allocation of profits non-uk activities, significant people functions, risks & capital
21 What remains unaffected? Passive commercial investment assets with Jersey owner subject to income tax as Non-Resident Landlord Not reliant on Treaty benefits or hybrids No changes to UK territorial scope of taxation on capital gains from commercial property No DPT provided income tax paid on rental income and not structured to increase UK income deductions
22 Connecting for Good Growth Ben Robins, JFA Chairman Connecting for Good Growth 20 October 2015 PwC
23 Plenty of scope for complacency JPUT formation and JPUT transactions = buoyant House-hold name" RE promoters abound: L&G, Aviva, BlackRock, UBS, Schroder, Henderson, LaSalle, Grosvenor, Threadneedle, Pramerica Non-UK investors (eg SWFs) embracing Jersey RE structures At 31 December 2014, value of real estate business in Jersey had grown by AIFMD NPPR is working + v positive ESMA AIFMD passporting opinion in July 32% in 12months highest ever level Service providers struggling to recruit
24 Warning signs on the dash-board? UK/London RE overheating? Over-reliance on UK RE assets/activity Likely delay in AIFMD 3rd country passporting 2016: new UK transparent RE fund structure with seeding relief benefits? Time to "smell the cheese" - prepare for and embrace change DPT/BEPS enhanced focus on permanent establishment and local substance requirements Reputational threats/competitors capitalising on uncertainty
25 Opportunities Short/mid-term: UK opportunities outside London Demonstrate credentials as a "smart" adopter of international transparency requirements (AML and tax) Capitalise on high quality PR resources (JFL internally) to counter reputational threats Capitalise on (but enhance) real estate substance credentials recruit even more RE-skilled personnel The global asset management pie is growing, but an increasingly fragmented market Capitalise on non- UK/EU opportunities (e.g. African RE and infrastructure development)
26 Strategic suggestions Government Acknowledge shifting skills requirements in immigration/fiscal policy (increased local "mind and management" but more out-sourcing of administrative functions). Sell International Finance Centre as a substantive hub. Ramp-up international tax team (for DTA/TIEA negotiations). Keep JFL funding at appropriate levels to counter reputational threats. Support "smart transparency" initiatives / link to Digital Jersey? Consider market-specific product development (e.g. a "Jersey for Africa" fund product?). JFSC Assist industry in streamlining AML processes post-moneyval. Continue market access dialogue with international regulators BUT; Sustain flexible regulatory models for as long as possible appeal to divergent global/investor appetites. Industry Remain well-briefed on tax developments. Engage with clients early in the change process be part of their solution + help achieve "BAU. Recruit now for the post-beps/dpt era. Be "sticky" - always offer superb, VATfree, tailored, support services. Dust-off the suit-cases: seek out smart, niche, areas globally.
27 Panel discussion Simon Hardwick, PwC UK John Mindham, PwC UK Ben Robins, JFA Chairman Connecting for Good Growth 20 October 2015 PwC
28 Conclusions Connecting for Good Growth 20 October 2015 PwC
29 Thank you! This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers CI LLP, its members, employees and agents do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it PricewaterhouseCoopers CI LLP. All rights reserved. PricewaterhouseCoopers refers to PricewaterhouseCoopers CI LLP (a limited liability partnership in the United Kingdom) or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity.
Jersey Funds Association UK taxation update
www.pwc.com/jg Jersey Funds Association UK taxation update 12 Contents Funds Real Estate Questions? 1 2 3 4 5 6 2 DIMF and changes to taxation of carried interest 3 The trilogy of tax changes The Disguised
Diverted Profits Tax 2015 briefing 21 April 2015
www.pwc.com/jg 2015 briefing Agenda 1 Diverted 2 How will Profits Tax background 5 6 What does this mean for you? Who will Diverted Profits Tax impact? Questions 3 4 Diverted Profits Tax work? Examples
Impact of BEPS and Other International Tax Risks on the Jersey Funds Industry
www.pwc.com/jg November 2015 Impact of BEPS and Other International Tax Risks on the Jersey Funds Industry Current International Tax Environment 1 2 The current environment The ability to achieve tax certainty
United Kingdom diverted profits tax now in effect
United Kingdom diverted profits tax now in effect Diverted profits tax (DPT) applies at a rate of 25% from 1 April 2015 to profits of multinationals that are considered to have been artificially diverted
BUSINESS IN THE UK A ROUTE MAP
1 BUSINESS IN THE UK A ROUTE MAP 18 chapter 02 Anyone wishing to set up business operations in the UK for the first time has a number of options for structuring those operations. There are a number of
Significant tax changes: UK implications for captive insurers
Tax Services Significant tax changes: UK implications for captive insurers Executive summary This alert sets out how recent developments in the global tax environment may impact UK-connected groups with
Jersey for Funds. Delivering Expertise, Flexibility and Innovation.
Jersey for Funds Delivering Expertise, Flexibility and Innovation www.jerseyfinance.je Jersey for Funds P1 A Tradition of Funds Expertise Jersey has been at the forefront of services for more than 50 years.
The UAE has joined the Inclusive Framework on BEPS
The UAE has joined the Inclusive Framework on BEPS May 2018 In brief The United Arab Emirates ( UAE ) joined the OECD Inclusive Framework on Base Erosion and Profit Shifting ( BEPS ) on 16 May 2018, bringing
1. Codifies transfer pricing rules, relief and provides for advance pricing arrangement (APA) regime to cater for unilateral,
JANUARY 2018 WWW.BDO.COM.HK HONG KONG TAX HONG KONG INTRODUCES TAX BILL TO IMPLEMENT MINIMUM STANDARDS OF THE BASE EROSION AND PROFIT SHIFTING TRANSFER PRICING REGULATORY REGIME AND DOCUMENTATION REQUIREMENTS
Corporate Residence update 26 & 27 November 2012
www.pwc.com Corporate Residence update 26 & 27 November 2012 Agenda 1. Who are we? 2. Company Residence 3. Substance 4. Permanent Establishment 5. How we can help Residence and Substance 6. UK s fight
UK PROPERTY TAXES COMMERCIAL AND RESIDENTIAL UPDATE JUNE 2018
UK PROPERTY TAXES COMMERCIAL AND RESIDENTIAL UPDATE JUNE 2018 TIMELINE OF TAX CHANGES The last few years have seen a transformation in the landscape for the taxation of property ownership in the UK with
7th Zurich Regional and Global Headquarters Conference Income tax accounting dealing with uncertainty and transparency
7th Zurich Regional and Global Headquarters Conference Income tax accounting dealing with uncertainty and transparency Changing tax landscape Anti Tax Avoidance Directive Country by Country Reporting Treaty
Tax Executives Institute Houston Chapter Tax accounting considerations of recent U.S. tax reform proposals May 4, 2017
www.pwc.com Tax Executives Institute Houston Chapter Tax accounting considerations of recent U.S. tax reform proposals Introductions Bret Oliver Tax Partner, (713) 356-8564 Bret.Oliver@pwc.com John Swilling
UK Taxation of Real Estate. Kathryn Wintle & Barry Curtis 23 April 2015
UK Taxation of Real Estate Kathryn Wintle & Barry Curtis 23 April 2015 Contents Background UK NRL compliance VAT considerations Stamp Duty Land Tax Annual Tax on Enveloped Dwellings Capital Gains Tax on
PROJECT TITLE UK PROPERTY TAXES UPDATE
PROJECT TITLE UK PROPERTY TAXES UPDATE 2017 TIMELINE OF TAX CHANGES The last few years have seen a transformation in the landscape for the taxation of property ownership in the UK with further changes
Roundup of Australia s BEPS developments
TaxTalk Insights Global Tax Roundup of Australia s BEPS developments 12 April 2017 In brief Since its presidency of the G20 in 2014, Australia has been at the forefront of efforts to combat tax avoidance
Tax Update. PwC Isle of Man, 14 November 2018
PwC Isle of Man, 14 November 2018 Today s agenda 1. 2018 Budget Update Kevin Cowley 2. UK Property Changes Andrew Cardwell 3. EU Listing Process - Substance Nicola Skillicorn, Deputy Assessor of Income
South Tees Hospitals NHS Foundation Trust Presentation to Governors Year ended 31 March 2015
www.pwc.co.uk July 2015 South Tees Hospitals NHS Foundation Trust Presentation to Governors Year ended 31 March 2015 Agenda Introductions Purpose of our reporting to governors Audit of the financial statements
Belgium November Paying Taxes th edition
Belgium Paying Taxes 2016 10 th edition www.pwc.com/payingtaxes The Paying Taxes methodology The three sub-indicators Both the tax cost and the tax compliance burden are important from the business point
Dubai International Financial Centre (DIFC) overhauls legal framework
Insights Tax and Legal Services PwC Middle East Dubai International Financial Centre (DIFC) overhauls legal framework November 2018 In brief The DIFC has repealed their Companies Law (DIFC Law No.2 of
Business considerations VAT and cash flow Intra GCC transactions There are a variety of opportunities to improve VAT cash flow and these typically involve deferring the payment of VAT due or improving
Innovation Incentives R&D Relief
www.pwc.co.uk Innovation Incentives R&D Relief Section 2 - Overview of R&D tax reliefs Introductions Who are we? James Geldart Senior Manager 07772 966342 Amy Lord Manager 07525 280680 Hayley Cowsill Senior
Financial Services Aircraft Leasing Forum
www.pwchk.com Financial Services Aircraft Leasing Forum How to structure an aircraft leasing fund? On 22 November 2017, PwC hosted its second Financial Services Aircraft Leasing Forum at our PwC office
Hotels, Healthcare & Student Housing are on the rise
Hotels, Healthcare & Student Housing are on the rise 1. Setting the scene The term alternative originates from the medieval Latin alternativus and is defined by the Cambridge dictionary as something that
BUSINESS MODELS IN THE CURRENT BEPS ENVIRONMENT DO YOU NEED TO CHANGE? Lyndon James, Partner Pete Rhodes, Senior Manager PwC
BUSINESS MODELS IN THE CURRENT BEPS ENVIRONMENT DO YOU NEED TO CHANGE? Lyndon James, Partner Pete Rhodes, Senior Manager PwC Agenda The current environment and the case for change Australian measures most
Budget Seminar Overcoming the storm Chai Sui Fun and Falgun Thakkar PwC Singapore
www.pwc.com.sg 2014 Budget Seminar Transfer pricing Overcoming the storm Chai Sui Fun and Falgun Thakkar g PwC Singapore Agenda 1. Update on global transfer pricing developments 2. Transfer pricing i documentation
IMPACT OF TAX ON M&A. Simon Fletcher 14 October 2016
IMPACT OF TAX ON M&A Simon Fletcher AGENDA 1. Tax environment 2. Recent developments 3. Impact on M&A 4. Questions Disclaimer: this presentation is intended to be for general guidance on matters of interest,
Brave new world. The OECD s Base Erosion & Profit Shifting (BEPS) Action Plan poses immediate challenges for oil and gas companies.
Brave new world The OECD s Base Erosion & Profit Shifting (BEPS) Action Plan poses immediate challenges for oil and gas companies December 2015 Introduction Already on the radar of governments and regulatory
Europe's Best Kept Secret
www.pwc.pt Why Portugal is your top tax choice 2012 Leendert Verschoor Portugal Among the 20 most visited countries in the world Portuguese language is spoken by about 230 million people around the world
Diverted Profits Tax. Key points
Diverted Profits Tax Given the publicity surrounding the practices of multinationals in particular a number of the large US technology corporations - in structuring their affairs to minimise their tax
Tax First Keeping you up-to-date with tax Issue No. 61 September 2011
www.pwc.co.uk/tax Tax First Keeping you up-to-date with tax Issue No. 61 Tax First Welcome to the September issue of Tax First With the holidays now over and autumn upon us, the wheels of the tax industry
DIVERTED PROFITS TAX Navigating your way
DIVERTED PROFITS TAX Navigating your way 1 Diverted Profits Tax: Navigating your way Diverted Profits Tax 5 key points you need to know 01 02 03 04 05 Diverted Profits Tax ( DPT ) is a new tax aimed at
Patent Box 29 May 2012
www.pwc.com Agenda Overview of patent box relief Will the company qualify? - Eligibility If so, what s the size of the prize? - Computation - 3 stage method - Alternative streaming method How to optimise
Comparison of Key Anti-Base Erosion Rules in the Tax Reform Act of 2017 and under UK Tax Law Calum Dewar, PwC Mike Williams, HM Treasury
Comparison of Key Anti-Base Erosion Rules in the Tax Reform Act of 2017 and under UK Tax Law Calum Dewar, PwC Mike Williams, HM Treasury International Tax Policy Forum and Institute of Economic Law Conference
Are you taking Russian tax risks? Time to test your Russia-related business. Check your tax risks factors and assess your risks
Are you taking n tax risks? Time to test your -related business Check your tax risks factors and assess your risks Why is it so important? n tax law is changing. So is the court practice. During times
2017 APEC CEO Survey Key Findings
A world in transition: PwC s 2017 APEC CEO Survey 2017 APEC CEO Survey Key Findings www.pwc.com/apec Key themes Making of the workforce of the future An operating model for a fluid trade policy environment
Non-resident capital gains taxation on direct and indirect sales of UK property
July 2018 Draft Finance Bill clauses Non-resident capital gains taxation on direct and indirect sales of UK property Summary of proposals Gains on disposals of all UK property and certain UK property rich
HMRC s Profit Diversion Compliance Facility
January 2019 Tax services HMRC s Profit Diversion Compliance Facility Why should businesses register? Overview of the disclosure facility On 10 January 2019 HMRC announced and launched a new disclosure
OECD releases final BEPS package
6 October 2015 Tax Flash OECD releases final BEPS package On 5 October 2015, the OECD published the final reports of the OECD/G20 Base Erosion and Profit Shifting ( BEPS ) project, which consist of a package
New format of the auditor s report
New format of the auditor s report New format of the audit report Auditor s opinion What the auditor s has audited identification of financial statements Audit approach: Audit scope Key Audit Matters How
Mauritius enacts changes to tax regime for corporations with global business licenses
17 August 2018 Global Tax Alert Mauritius enacts changes to tax regime for corporations with global business licenses NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is
KPMG Private Equity Forum. 11 December 2017
KPMG Private Equity Forum 11 December 2017 Agenda Introduction Nick Stevens KPMG CI Brexit and the fundraising considerations Iain Bannatyne Ben Honeywood KPMG UK KPMG CI EU Blacklisting update John Riva
Passive Foreign Investment Companies (PFICs) and Controlled Foreign Corporations (CFCs)
www.pwc.com Passive Foreign Investment Companies (PFICs) and Controlled Foreign Corporations (CFCs) Yair Zorea, Tax Partner, Sara Levy, Tax Manager, PFIC Overview The Passive Foreign Investment Company
CONTROLLED FOREIGN COMPANIES
CONTROLLED FOREIGN COMPANIES PRESENTATION BY [NAME] [DATE] OUTLINE 1. Controlled Foreign Company ( CFC ) The Concept 2. CFC International scenario 3. BEPS Action Plan 3 THE CONCEPT CFC THE CONCEPT CFC
United Kingdom Tax Alert
International Tax United Kingdom Tax Alert Contacts Bill Dodwell bdodwell@deloitte.co.uk Christie Buck cbuck@deloitte.co.uk Alison Lobb alobb@deloitte.co.uk 11 December 2014 Draft legislation on diverted
The conference covered the following themes, which will be summarised in this briefing:
LMA Real Estate Finance Conference Key Themes The LMA's fourth Real Estate Finance Conference was held in London on 11 May 2016. The conference consisted of a series of panel discussions and presentations
Investment Management Association of Singapore. Annual Conference 2015
www.pwc.com/assetmanagement Investment Management Association of Singapore Annual Conference 2015 26 March 2015 Panel Discussion: The Rise of Regional Passporting Schemes in Asia Your Panel Today Panel
MAS Enhanced Regime for Funds Management
www.pwc.com MAS Enhanced Regime for Funds Management A new landscape for Fund Management Companies Are you ready? IMAS Lunchtime Series IMAS Lunchtime Series 29 &31 August 2012 Agenda Background What does
UK HMRC issues update on diverted profits tax
20 March 2015 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date UK
Finance Bill 2016 summary of key changes for fund managers
Finance Bill 2016 summary of key changes for fund managers On 24 March 2016 the Government published the Finance (No. 2) Bill 2016. One of the most relevant aspects of the finance bill for alternative
Analysis of BEPS Action Plan 3 Strengthening CFC Rules
Analysis of BEPS Action Plan 3 Strengthening CFC Rules 1. Introduction Pavan R Kakade* Puneet Putiani** With the increase in globalization and foreign trade in the last century, taxpayers have been resorting
Indirect tax forum VAT establishments April 2018
www.pwc.co.uk Indirect tax forum VAT establishments Agenda VAT establishments basic principles Hastings Insurance Services Ltd - implications 1 2 Topical issues Questions 2 3 4 4 2 What are the basic principles?
Global Transfer Pricing Conference
www.pwc.com/transferpricing Global Transfer Pricing Conference Financial transactions the centre of attention October 2016 The new normal full TransParency Today s presenters Jeff Rogers Canada Nick Houseman
UK Tax Authority launches Profit Diversion Compliance Facility
10 January 2019 Global Tax Alert UK Tax Authority launches Profit Diversion Compliance Facility NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized
Brexit and Financial Services: The Final Countdown
Brexit and Financial Services: The Final Countdown Grania Baird and Kya Fear 05 November 2018 With less than five months before the UK leaves the EU there is no final consensus on a withdrawal agreement,
Portugal 2015 October 2015 Restricted use Kevin Valenzia
www.pwc.com/mt Malta Portugal 2015 Restricted use Kevin Valenzia Agenda Kevin Valenzia - ( Malta), Malta tax and other matters Jaime Esteves - ( Portugal), Portuguese fiscal matters Robert Walker - (Rathbone
A New Regime for European Venture Capital Response Registered Association
First Floor North Brettenham House Lancaster Place London WC2E 7EN Dear Sirs A New Regime for European Venture Capital Response Registered Association 82506726362-20 The British Private Equity and Venture
The UK as a favoured location for Indian investments
The UK as a favoured location for Indian investments Over the course of multiple parliaments under different political leadership, UK Government policy has consistently aimed at creating the most competitive
THE FUTURE OF TAX PLANNING: TRANSPARENCY AND SUBSTANCE FOR ALL? Friday, 26 February AM PM Conrad Hotel, Hong Kong
THE FUTURE OF TAX PLANNING: TRANSPARENCY AND SUBSTANCE FOR ALL? Friday, 26 February 2016 9.00AM - 12.00PM Conrad Hotel, Hong Kong THE DRIVE TOWARDS TRANSPARENCY: CHALLENGES AND OPPORTUNITIES IN INTERNATIONAL
Fund Structures 6 October 2015
Fund Structures 6 October 2015 Welcome Paolo Alonzi Head of Real Estate Finance & Operations Standard Life Investments Agenda Moderator Paolo Alonzi, Head of Real Estate Finance & Operations, Speakers
On course for competitiveness. Budget survey 2014
On course for competitiveness Budget survey 2014 Executive summary With an election looming next year and EY s ITEM club predicting a modest upgrade to the short-term forecast for economic growth, the
7th Global Headquarters Conference Swiss Tax Update in the international context
Tax and Legal Services 7th Global Headquarters Conference Swiss Tax Update in the international context Welcome! Your Speakers Armin Marti Partner, Leader Corporate Tax Switzerland Direct: +41 58 792 43
VAT Package March 2010
VAT Package March 2010 On 1 January 2010, the EU introduced a package of changes to the VAT rules that affected Law Firms. The VAT Package has resulted in significant change to all Law Firms with establishments
Autumn Tax Update. Tony Mancini, Paul Beale & Sinéad Leddy. 23 November 2017
Autumn Tax Update Tony Mancini, Paul Beale & Sinéad Leddy 23 November 2017 Agenda 1. Welcome and introduction 2. UK Chancellor s Autumn Statement 3. Paradise Papers 4. EU screening process 5. Questions
TAX & LEGAL ISSUES ASSET MANAGEMENT
TAX & LEGAL ISSUES ASSET MANAGEMENT Kevin Cummings, Tax Partner (BDO) Claire Cummings, Partner (Cummings Law) March 2015 Contents Disguised fee draft legislation Diverted profits tax BEPS and UK action
A world in transition: PwC s 2017 APEC CEO Survey, November APEC CEO Survey. Malaysia s findings.
A world in transition: PwC s 2017 APEC CEO Survey, November 2017 2017 APEC CEO Survey Malaysia s findings www.pwc.com/apec Key themes Making of the workforce of the future An operating model for a fluid
A world in transition: PwC s 2017 APEC CEO Survey, November APEC CEO Survey. The Philippines findings.
A world in transition: PwC s 2017 APEC CEO Survey, November 2017 2017 APEC CEO Survey The Philippines findings www.pwc.com/apec Key themes Making of the workforce of the future An operating model for a
Beneficial Ownership and Control
Beneficial Ownership and Control FAQs for Trust Company Service Providers (TCSPs) The Changes The Companies Registry at the Jersey Financial Services Commission (JFSC) is making changes to the way the
The impact of taxes on the competitiveness of European Tourism
PwC UK The impact of taxes on the competitiveness of European Tourism European Commission (DG GROW) 9 November 2017 Overview 3 The PwC team with you today 4 The importance of tourism for the EU 5 Overview
Transfer pricing interaction
A practical approach to the DPT Much has been written about the rights and wrongs of the Diverted Profi ts Tax included in Part 3 of the Finance Act 2015. This article faces up to the reality that it is
ETFs: A BEGINNER S GUIDE. November 2018
ETFs: A BEGINNER S GUIDE November 2018 The purpose of this guide is to provide an introductory guide to exchange traded funds ( ETFs ) in Europe. We note that this guide has been made available to the
FSRR Hot Topic. European Banking Authority Brexit opinion: what does it mean for firms Brexit plans?
www.pwc.co.uk/fsrr October 2017 Stand out for the right reasons Financial Services Risk and Regulation FSRR Hot Topic European Banking Authority Brexit opinion: what does it mean for firms Brexit plans?
Taxing times Indirect tax forum
www.pwc.co.uk Indirect tax forum 5 Agenda 13.30 Registration 14.00 Welcome and update on hot topics Martin Blanche, 14.20 Workshop session 1 15.00 Tea break 15.20 Workshop session 2 16.00 Guest speaker
UK U P D AT E A N D T H E I M PA C T O F B R E X I T H L B N O R T H A M E R I C A N TA X C O N F E R E N C E D E C E M B E R 2016
UK U P D AT E A N D T H E I M PA C T O F B R E X I T H L B N O R T H A M E R I C A N TA X C O N F E R E N C E D E C E M B E R 2016 INTRODUCTION UK update and the impact of Brexit The UK in 2016 Impact
Deferred Compensation: Details You Want to Know. NACUBO Tax Forum Joseph D. Olivieri, PwC October 21, 2013 St. Louis, Missouri
Deferred Compensation: Details You Want to Know NACUBO Tax Forum Joseph D. Olivieri, PwC October 21, 2013 St. Louis, Missouri Agenda PwC Slide 2 Goals of a Deferred Compensation Program Types of Deferred
QUESTIONNAIRE ON THE TREATMENT OF INTEREST PAYMENTS AND RELATED TAX BASE EROSION ISSUES
QUESTIONNAIRE ON THE TREATMENT OF INTEREST PAYMENTS AND RELATED TAX BASE EROSION ISSUES This questionnaire should be completed by participants in United Nations capacity development programs on protecting
HMRC consultation on tax deductibility of corporate interest expense
Submitted via email to: BEPSinterestconsultation@hmtreasury.gsi.gov.uk 4 August 2016 RE: HMRC consultation on tax deductibility of corporate interest expense Dear Sirs, BlackRock [1] is pleased to have
Tomorrow s World Conference December 2013
www.pwc.com Tomorrow s World Asia Pacific Real Estate Conference 2013 6 December 2013 www.pwc.com Singapore Structuring Investments into Singapore Real Estate Teo Wee Hwee Partner, International Tax, Funds
TAX STRATEGY AND APPROACH TO TAX
TAX STRATEGY AND APPROACH TO TAX We are not just a British bank we take pride in being a bank for Britain, at the heart of the UK s economy. This document summarises our approach to tax. In line with our
The FSB Task Force on Climate-related Financial Disclosures What do its recommendations mean for the energy sector?
www.pwc.co.uk The FSB Task Force on Climate-related Financial Disclosures What do its recommendations mean for the energy sector? June 2017 An introduction to the Task Force TCFD established The G20 Finance
INTERNATIONAL INVESTORS TO BE LIABLE TO UK TAX ON CAPITAL GAINS DERIVED FROM UK REAL ESTATE FROM 2019
November 24, 2017 INTERNATIONAL INVESTORS TO BE LIABLE TO UK TAX ON CAPITAL GAINS DERIVED FROM UK REAL ESTATE FROM 2019 To Our Clients and Friends: Background 1.1 The UK has the largest commercial property
Diverted Profits Tax Guidance. Guidance 10 December 2014
Diverted Profits Tax Guidance Guidance 10 December 2014 1 Contents Page Introduction Chapter 1 Chapter 2 Chapter 3 Introduction & Overview Application of Diverted Profits Tax Diverted Profits Tax - processes.
Egypt updates Transfer Pricing Guidelines
Egypt updates Transfer Pricing Guidelines October 2018 In brief On 23 October 2018, the Egyptian Tax Authority ( ETA ) published an update to the Egyptian Transfer Pricing Guidelines ( ETPG ) which were
A world in transition: PwC s 2017 APEC CEO Survey, November APEC CEO Survey. The United States findings.
A world in transition: PwC s 2017 APEC CEO Survey, November 2017 2017 APEC CEO Survey The United States findings www.pwc.com/apec Key themes Making of the workforce of the future An operating model for
Expanding your footprint
www.pwc.com/sg Expanding your footprint How PwC s Asian Investment Fund Centre can help you expand your footprint in the Asian and European fund industry Supporting you in creating, delivering and maintaining
Setting-up shop in the US - tax aspects
www.pwc.com Setting-up shop in the US - tax aspects Andreea Mitirita, Tax Director, Romania Agenda 1 Overview of the US tax system 2 3 Common structures for US expansion Q&A 2 Overview of US tax system
A New European Regime for Venture Capital
Ref. Ares(2011)1001117-21/09/2011 A New European Regime for Venture Capital Response of the Law Society of England and Wales ETI Registration number: 24118193117-34 The Law Society of England and Wales
CROSS-BORDER FINANCING The Hidden Cost of Capital. Ka Sen Wong Allen & Overy
CROSS-BORDER FINANCING The Hidden Cost of Capital Ka Sen Wong Allen & Overy Overview The current environment Anti-hybrid rules Diverted profits tax Chevron Suggested actions Tax is front page news Senate
United Kingdom Tax Alert
International Tax United Kingdom Tax Alert Contacts Bill Dodwell bdodwell@deloitte.co.uk Christie Buck cbuck@deloitte.co.uk Alison Lobb alobb@deloitte.co.uk 4 December 2014 2014 Autumn Statement contains
OECD releases final report on CFC rules under BEPS Action 3
11 October 2015 Global Tax Alert EY OECD BEPS project Stay up-to-date on OECD s project on Base Erosion and Profit Shifting with EY s online site containing a comprehensive collection of resources, including
A global focus on the investment management industry
International Tax for Asset Managers update Fall 2017 A global focus on the investment management industry In this issue (Please note: the content in this issue was written by Deloitte UK): United Kingdom:
Consultation Paper CP29/17 International banks: the Prudential Regulation Authority s approach to branch authorisation and supervision
Consultation Paper CP29/17 International banks: the Prudential Regulation Authority s approach to branch authorisation and supervision December 2017 Consultation Paper CP29/17 International banks: the
Diverted Profits Tax. The Royal Society 6-9 Carlton House Terrace London SW1Y 5AG. 08 January 2015
Diverted Profits Tax The Royal Society 6-9 Carlton House Terrace London SW1Y 5AG 08 January 2015 Agenda 09.00 09.30 Registration 09.30 09.35 Open - Aidan Reilly (HMRC) 09.35 09.45 Policy Context and Overview
Foreign Tax Alert Stay informed of new developments
Singapore Tax 8 December 2014 Foreign Tax Alert Stay informed of new developments Capital Gains Tax and UK residential property On 27 November 2014 the UK government published its response to the consultation
ASOS plc Group Tax Strategy
ASOS plc Group Tax Strategy Updated October 2016 ASOS plc Group Tax Strategy Introduction The aim of this document is to set out the strategic objectives of the ASOS plc ( The Group ) with regard to tax,
Non-resident companies subject to income tax
Introduction 1. The BPF represents the UK real estate sector an industry with a market value of 1,662bn and that employs 1 million people. We promote the interests of those with a stake in the UK built
2014 Budget Seminar. Tax Risk Management in
www.pwc.com/sg 2014 Budget Seminar Tax Risk Management in changing fiscal climate Paul C. and Mahip G. p PwC Singapore Agenda Changing Tax landscape factors driving the change Current Development reflecting
Non-resident chargeable gains on UK property collective investment vehicles
January 2019 Draft Finance Bill clauses Non-resident chargeable gains on UK property collective investment vehicles Summary of draft rules for collective investment vehicles (CIVs) In addition to the new
UK issues Summer Budget 2015
10 July 2015 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date UK issues
Release of BEPS discussion draft: Make Dispute Resolution Mechanisms More Effective
from Tax Controversy and Dispute Resolution Release of BEPS discussion draft: Make Dispute Resolution Mechanisms More Effective December 22, 2014 In brief On December 18, 2014, the Organisation for Economic