The Global Tax Reset 2017 Audit Committee Symposium

The Global Tax Reset General context Multinational companies are subject to many tax-related challenges Perception MNCs are not paying fair share of taxes Loss of trust between tax authorities and business Countries requesting greater allocation of profit Government deficits, media attention and activist group interest has resulted in political interest in increasing the taxes paid by multinational enterprises. Copyright 2017 Deloitte Development LLC. All rights reserved. 2017 Audit Committee Symposium Anticipate. Navigate. Focus. 2

The Global Tax Reset Overview of ongoing changes Change in tax authorities approach to interpretation of tax law and tax treaties Responsible Tax agenda OECD s BEPS project EU Commission Tax Avoidance Package and State Aid Unilateral action Digital Economy BEPS is part of the bigger picture Copyright 2017 Deloitte Development LLC. All rights reserved. 2017 Audit Committee Symposium Anticipate. Navigate. Focus. 3

Impact of BEPS / EU ATAD BEPS / ATAD overview and timeline OECD BEPS project EU ATAD Minimum standards Treaty abuse CbC reporting Permanent establishment Harmful tax practices Dispute resolution Transfer pricing CFC rules Anti-Tax Avoidance Directive Interest restrictions Hybrid mismatches Exit taxation General anti-abuse rule Common approach Best practices Interest restrictions Hybrid mismatches Transfer pricing documentation CFC rules Disclosure rules Jan. 1, 2019 CFC Interest deduction restriction Exit tax GAAR Jan. 1, 2020 Most hybrid mismatch 1 provisions April 2017Nove mber 2015 Jan. 1, 2022 Specific reverse hybrid mismatch provisions Copyright 2017 Deloitte Development LLC. All rights reserved. 2017 Audit Committee Symposium Anticipate. Navigate. Focus. 5 Copyright 2017 Deloitte Development LLC. All rights reserved. FOR INTERNAL USE ONLY The Netherlands Hot Topics

Background 68 jurisdictions joined the convention on 7 June 2017 Andorra Argentina Armenia Australia Austria Belgium Bulgaria Burkina Faso Canada Chile China Colombia Costa Rica Croatia Cyprus Czech Republic Denmark Egypt Fiji Finland France Gabon Georgia Germany Greece Guernsey Hong Kong Hungary Iceland India Indonesia Ireland Isle of Man Israel Italy Japan Jersey Korea Kuwait Latvia Liechtenstein Lithuania Luxembourg Malta Mexico Monaco Netherlands New Zealand Norway Pakistan Poland Portugal Romania Russia San Marino Senegal Serbia Seychelles SingaporeSlovak Republic Slovenia South Africa Spain Sweden Switzerland Turkey United Kingdom Uruguay Copyright 2017 Deloitte Development LLC. All rights reserved. 2017 Audit Committee Symposium Anticipate. Navigate. Focus. 7

Ongoing OECD Efforts Digital Economy Cooperative Compliance Certainty Minimum Standards Peer Reviews Copyright 2017 Deloitte Development LLC. All rights reserved. 2017 Audit Committee Symposium Anticipate. Navigate. Focus. 9

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