european fiscal services [email protected]
TRANSCRIPT
The Future of Tax Practice BKR Worldwide Meeting
Dublin, Ireland 2013
European Fiscal Services Ltd [email protected]
The Future of Tax Practice 2013
Ian E Hayes FCA FIIT CTA FRSAVice President C.F.E.
Consultant Tax Adviser
European Fiscal Services Ltd [email protected]
European Fiscal Services Ltd [email protected]
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Our Time Today
Highlights of the millennium years Current Drivers The Next 2 years Tax Practice of the future Discussion points
October 2013
European Fiscal Services Ltd [email protected]
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2001 -2013 - 1
Client Relations Software developments
› Professional› State sponsored
Old methods new problems Pressure on fees
October 2013
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2001 -2013 - 2
Anti Money laundering Regulation and Competition Tax Avoidance/Abuse
› Ethics› Client expectation› State reaction
The need to invest
October 2013
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Current Drivers - 1
G8 to G20 Revenue Authorities OECD Tax Activists and NFPs Highly visible corporate planning The Politics of tax havens
October 2013
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Current Drivers - 2
BEPS› Base Erosion and Profit Shifting
OECD Global Tax Forum› Automatic exchange of information
OECD 15 point plan› G20 plus 16 committed to reform of global
taxation model
October 2013
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Current Drivers - 3
› The search for Transparency Consistency Certainty
› Tax “fairness”
October 2013
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Finished by September 2014?
The Digital Economy Prevent Treaty Abuse Neutralise hybrid mismatch
arrangements Prevent the artificial avoidance of P.E.
Status Re-examine transfer pricing
documentation
October 2013
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December 2014 – In Progress To complete by September 2015 ?
Counter harmful tax practices transparency and substance
Transfer pricing outcomes in line with intangible value creation
Develop a multilateral instrument
October 2013
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Finished by September 2015 ?
Strengthen CFC rules Limit base erosion by interest and other financial
payments Transfer pricing outcomes in line with risk and
capital value creation Transfer pricing outcomes in line with other high
risk transaction value creation Methods to collect and analyse BEPS data –
actions to address Disclosure of aggressive tax planning by
taxpayers Effective dispute resolution mechanisms
October 2013
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The Global Tax Forum
Automatic bilateral exchange of information
October 2013
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Tax Practice in the Future – 1 Bread and butter issues
Compliance Risk management
› Client› Authority› Staff
Tax in a changing environment
October 2013
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Tax Practice in the Future – 2 Expenditure and Investment
Training Software Practice assured
October 2013
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Tax Practice in the Future – 3 Good boy syndrome
Tax Planning for clients Avoidance issues The Australian Experience What registration really means Client/Revenue/Arbitrator?
October 2013
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Tax Practice in the Future – 4 Sandwich filling?
Forensic Recovery Restoration Support through litigation Untying the knots Cross border transactions New Taxes
October 2013
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Tax Practice in the Future - 5 – Points for discussion
Risks involved Where does the profit come from Relations with clients Relations with revenue Regulation, Registration or laissez faire
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European Fiscal Services Ltd [email protected] 19
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Thank you! Food for thought?
October 2013