EMEA conference Transforming tax making it work. The Crystal, London 9-10 June 2015

Transcription

1 EMEA conference Transforming tax making it work The Crystal, London 9-10 June

2 EMEA conference Plenary 1 Transformation why? 2

3 Transformation why? External trends are impacting tax As business GLOBALIZES so do tax obligations together with a pressure for centralized global delivery Increased REGULATION makes business more complex but also more transparent... raising risk and enabling mainstream media coverage TECHNOLOGY proliferation fuels expectations for wholesale process change, and becomes a catalyst for reengineering tax TALENT new skills are needed and there is a new environment within which to attract and retain people Transformation of REVENUE AUTHORITIES the way they go about their work New STAKEHOLDERS have emerged and we are confronted by a new era of socially responsible tax

4 Legislative changes 4

5 The story so far Disclosure Of Tax Avoidance Schemes Tax in the Boardroom Senior Accounting Officer Digital bookkeeping and filing Transparency 5

6 International response OECD s Base Erosion & Profit Shifting study The European Response State Aid Tax Rulings Action Plan on Corporate Taxation Unilateral measures 6

7 What does it mean? More taxes in more jurisdictions at greater expense Modelling the impact How? When? 7

8 UK BEPS timetable September 2014 October 2015 December 2015 Digital economy Hybrid mismatches Treaty abuse Transfer pricing documentation Transfer pricing of intangibles Harmful tax practices Multilateral instrument Permanent establishments Transfer pricing of intangibles, risks and capital, other CFC Disclosure Dispute resolution Interest restrictions Harmful tax practices Data collection and analysis Interest (pricing) Harmful tax practices Multilateral instrument 8

9 UK BEPS timetable Country-by-country reporting The Chancellor has confirmed the implementation of G20 / OECD model for country-by-country reporting to tax authorities into UK legislation Regulations will follow to implement the template which will include reporting by country, including entity list and activities on: Revenues (split between related and unrelated parties); profit before tax; cash tax paid; current tax accrued; number of employees; tangible fixed assets; share capital; and accumulated earnings 9

10 UK BEPS timetable Hybrid mismatches consultation on introducing measures into UK from 1 January 2017 Harmful tax practices Wholesale re-write of UK patent box policy Move away from transfer pricing principles to modified nexus approach Current scheme closed to new entrants from 1 July 2016 Current scheme repealed by 1 July

11 Pervasive information technology 11

12 Pervasive information technology Ambient computing The merging of the physical and the virtual world Information rules The API Economy Amplified intelligence The next generation of knowledge systems 12

13 Pervasive information technology Cyber and data privacy Managing the acquisition and custody of information Complexity and change Picking a path through the tax technology jungle 13

14 Why look at your tax technology architecture? Tax technology landscape 14

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