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TRANSCRIPT
2018
Company Profile
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Connecting the world‘s leading tax experts
» Over 100 hand-picked partner firms
» Recent tax awards within WTS Global include (inter alia)
› Chambers and Partners
• Tier 1 ranked global network 2017 • WTS Global
(continuously since 2012)
› International Tax Review
• European Indirect Tax Firm of the Year 2018 • WTS Global
• Germany Transfer Pricing Firm of the Year 2018 • WTS Germany
• Austria Tax Firm of the Year 2018 • ICON
• Ukraine Transfer Pricing Firm of the Year 2018 • WTS Consulting/KM Partners
• India Tax Firm of the Year 2018 • Dhruva Advisors LLP
• India Tax Disputes & Litigation Firm of the Year 2018 • Dhruva Advisors LLP
• Philippines Tax Disputes & Litigation Firm of the Year 2018 • BDB Law
• Asia Tax Policy Firm of the Year 2018 • BDB Law
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Global key values - our corporate DNA
» Loyal partners, keeping our promises
» Quick response times and needs-based solutions
» Responsible conduct and long-term strategy of cooperation
» Open-minded: Having an entrepreneurial spirit
» Keen-spirited: Always curious about new developments and trends
» Inquisitive challengers: Creating inventive solutions for ever-changing challenges
» Forward thinkers: Pioneering digitalization and the development of IT tax tools
» Working with pleasure and enthusiasm
» Taking responsibilities and objectives with a high degree of personal commitment
» Fully dedicated and people-focused: supportive and caring
» Technical competence of the highest standards
» Top quality services
» Highly efficient, customized implementation of practical solutions
» Unique expertise based on multiyear experience in industry, financial management and consultancy
ExcellentInnovative
Passionate Reliable
WTS at a glance
9 offices in Germany > 800 employees
> 120 Mio. €* revenue: 80% from tax advice
Global network > 100 countries
Independent & free of conflict: No audit
Tax-focused: Additional expertise in legal consulting and financial advisory
Innovative: Future-proof solutions
Diverse customer base: From multinationals to private clients
4*Estimated revenue FY 18/19
Our global client portfolio: Supporting a broad range of clients from all industries
» Multinational companies
» Small and medium-sized companies
» Non-profit organisations
» Private clients & family offices
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Offering a fully-fledged tax service portfolio globally
» Corporate Tax
» Mergers & Acquisitions
» Transfer Pricing & Valuation Services
» Indirect Tax
» Customs
» Private Clients & Family Office Services
» Global Mobility
» Tax Controversy
» International Tax and Permanent
Establishments (ITP)
» Financial Services
» Real Estate
» Tax Technology
Global services
Additional cross-cutting services
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Shaping the future by anticipating trends
BEPS – Litigation and Arbitration
Digitisation
Tax Control Framework
Business Partnering
EU Audit Reform US Tax Reform
VAT in the GCC
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Trend: Business Partnering
Pioneering innovative tax partnerships
» Client benefits
» Increasing quality and flexibility
» Reducing overall costs
» Retaining in-house expertise and gaining permanent access to specialists around the world
» Keeping governance and control in-house
» Choice of tailored scope of services
» Saving resources for strategic activities
» WTS Experience
» > 15 years (WTS Germany)
» 50% of WTS Germany’s turnover
“A pioneered deal” by International Tax Review
(Feb 8, 2017)
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Designing digitisation proactively
Tax sector is changing
Global trend: Digitisation
Opportunities for companies WTS develops individual, future-proof solutions
» Tax processes are re-defined and largely automated worldwide
» Integration of mass data, artificial intelligence (AI) and IT tools
» Increased process and cost efficiency
» Increased compliance safety, minimisation of liability risks
» Many years of experience in digital process consulting
» In-house tax tool experts
» Validated set of IT tax tools
» Evaluation of innovative concepts in cooperation with top researchers
» Establishment of solutions which closely link tax functions and business processes
BEPS: Generating benefits from obligations
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A total of 15 action items of the OECD against aggressive tax planning
Trend: BEPS (Base Erosion and Profit Shifting)
Opportunities
Smart use of process-supporting tools:
» Minimising tax risks
» Fulfilling reporting requirements in a reliable and efficient way
» Using data in parallel with optimisation of the existing transfer pricing system
Need for action
!
7: Permanent establishments
Checking existing structures and projects for undetected permanent establishments
13: Documenting transfer prices
» Introducing Master File(revenue ≥ € 100m)
» Preparing a country-by-country report (consolidated revenue ≥ € 750m)
Tax Control Framework: Minimising error rates and liability risks
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Global trend: Tax Control Framework
Cooperative Compliance
» Internal revision
» Tax audit (incl. joint audit)
» Audit
» Control
» Data analytics / mass data
» Tax audit simulation
› Profit tax
› Sales tax
› Income tax
› Customs duties
» Analysis
» Timely company audit
» Tax control framework
» Checking processes and systems through tax audit
» Use of tax technology
» Prevention
EU Audit Reform: Consulting without conflict – only with WTS
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Trend: EU Audit Reform
!
* Affects, for example, US investors** Cooling-in phase is 6 years; joint audit is obligatory if company is a PIE, i.e. basically two auditing companies are „conflicted“
Many companies are affected, especially capital market-oriented companies,
banks and insurance companies
» Germany
» Prohibited non-audit services during cooling-in phase (1 year) and auditing activities:
› Customs, income tax, tax control framework, tax asset management
› Tax advisory services with considerable reduction of the tax base or with transfer of profits to foreign countries, e.g. group structure, transfer pricing, Luxembourg/Ireland Model*
» Fee cap: Permissive non-audit services of max. 70% of the average total fees of the past three years
» Other EU countries
» Increased complexity with transnational activities
» Due to stronger regulations by numerous EU countries, it is necessary to frequently change advisors abroad, e.g.
› Basic prohibition of tax advisory services, e.g. in France
› Expansion of affected companies, e.g. Italy, Spain
› Longer cooling-in periods, e.g. France**, Portugal, The Netherlands
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US Tax Reform: Increasing global competitiveness
Global trend: US Tax Reform
» Intended to encourage domestic growth and make the US Tax Regime more competitive globally
» No tax legislation currently in progress
» Timing delayed due to Administration decision to repeal Obamacare as first priority
» 2017 enactment questionable
Possible components of corporate tax reform
» Reduced corporate income tax rate (various
rates from 15% to 20% have been proposed)
» Move from worldwide tax to a territorial tax
system
» Reduction or elimination of interest expense
deduction
» Eliminating various “special interest” deductions
and credits
» One-time tax on existing offshore deferred profits
» Eliminating a number of corporate deductions
» Immediate deductibility of cost of certain capital
investments
» Potential changes in Net Operating Loss rules
» Repeal of Medical Device Tax separately through
Healthcare legislation
True tax reform vs. Tax rate reduction?
Revenue neutrality vs. Increase to the deficit?
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VAT in the Gulf Cooperation Council: Introducing 5% VAT
Global trend: VAT in the GCC
» Opportunities
» Training
» Impact assessment and diagnostic reviews
» Tax advisory and strategy
» Implementation assistance and redesigning business processes
» VAT audit, compliance support and outsourcing
» Need for action
» Awareness
» Business impact
» Systems & documentation
» Compliance
» Introduction of 5% VAT in GCC covering the UAE, Bahrain, Saudi Arabia, Oman and
Kuwait
» Anticipated implementation in 2018
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Our global service lines and regions: Ensuring seamless project progress
Organised as a matrix structure
Americas
Asia Pacific
Africa
Europe
TP Indirect
Tax
M&A ITP* Private
Clients
Global
Mobility
Digital
Solutions
*International Tax & Permanent Establishments
Transfer Pricing (TP)
Scope of Services:
» Planning and implementation of TP systems and TP
policies
» OECD BEPS-compliant TP documentation and
economic analyses
» TP advice in business restructurings
» Defense in TP tax audit and litigation matters
» Advice and assistance in APAs and MAPs
» Valuation for TP purposes, including IP and exit
taxation matters
IT-Tools:
» TPmanager
» CbCR Manager
» CbCR-2-XML Manager
Areas of Focus / USPs:
» IT-supported solutions for transfer pricing
» Combined expertise from former in-house tax
departments, consulting and tax administration
» Interdisciplinary team of certified tax advisers
» Economists and lawyers
Jared Walls
Partner
Economics Partners (Morristown, NJ)
+1 (0) 530 301-1818
Maik Heggmair
Partner
WTS (Munich)
+49 (0) 89 28646-212
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Service line: TP
Service line: Indirect Tax
Indirect Tax
Scope of Services:
» VAT Risk Management
» VAT Compliance and Declarations
» Transactions and Restructurings
» Supply chain modelling
» Pro-rata calculations
» Ongoing VAT advice
» VAT Litigation
IT-Tools:
» VAT Manager
» VAT@GTC
» VAT Analyzer
» eVAT reporting
» TRACE-SII-REPORTINGmanager
Areas of Focus / USPs:
» Financial Services and Real Estate focus
» Specific VAT Technology know-how (including SAP &
Oracle configurations)
» European Indirect Tax Firm of the year 2017
2 Leading U.S.-based
Financial Institutions
Leading Global Insurance
& Funds Group
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Jürgen Scholz
Partner
WTS (Duesseldorf)
+49 (0) 211 2005-0677
Service line: M&A
Mergers & Acquisitions (M&A)
Scope of Services:
» Due Diligence
» Tax Structuring
» Tax Model Fund Flow Papers
» Management Participation
» SPA Advice
» Acquisition Financing
» Post-Deal Integration
Areas of Focus / USPs:
» Full scope offering in M&A Tax Services
» Additional full scope offering in M&A Financial Advisory
Services
» Our member firms are highly ranked in M&A tax
» Partner-led throughout the project
» Broad industry expertise
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Stefan Hölzemann
Partner, Managing Director
WTS (Munich)
+49 (0) 89 28646-1200
Service line: ITP
International Tax & Permanent Establishments (ITP)
Scope of Services:
» Tax consulting in project offer phase including
assessment of tax impacts/risks from a cross border
project in home and project country
» Tax advice and ongoing support after project win and
contract conclusion/prolongation
» Review and recommendations on tax clauses and other
tax relevant aspects of contracts
» Advice on HR and Social Security
» Permanent Establishment Tax Compliance
Areas of Focus / USPs:
» Strong focus but no limitation to construction,
engineering and service sector
» Permanent establishment (PE) related tax consultancy
and compliance assistance
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Sonja WiesnerDirector
WTS (Munich)
+49 (0) 89 28646-1260
Service line: GES
Global Expatriate Services (GES)
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Scope of Services:
» Tax consulting services incl.
› Arrival and exit meetings
› Preparation of tax declarations for individuals and
global coordination
› Preparation of assignment guidelines incl. design of
tax equalization models
› Advice on the avoidance and processing of
permanent establishments
» Legal Consulting Services incl.
› Contract drafting and review from a domestic and
foreign labor law perspective
› Examination of social security status incl.
application for certificates of coverage
› Advice on immigration law and application for visa,
resident and work permits
Areas of Focus / USPs:
» Well coordinated team and strong linkage with all our
partner firms
» Comprehensive support from a single source
» Integrated approach – tax, social security, labor and
immigration law
Frank Dissen
Partner
WTS (Frankfurt)
+49 (0) 69 133 84-5652
Service line: Private Clients
Private Clients
Areas of Focus / USPs:
» Interdisciplinary approach
» Team consists of tax experts and civil law professionals
» Extensive expertise in automating processes using tax
tools
IT-Tools:
» WTS - QPLIX asset controlling tool
Scope of Services:
» Expert advice in all tax and civil law matters for
companies and owners
» Solutions for successions, prenuptial and testamentary
agreements, and other life events
» Structures for the protection of assets (foundations,
trusts, limited companies)
» Preparation of tax returns, investments schemes,
income arrangements
» Assistance with charitable activities
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Dr. Franz Angermann
Partner
WTS (Munich)
+49 (0) 89 28646-1579
Gerd D. Goyvaerts
Partner
Tiberghien (Brussels)
+32 (0) 2 77340-00
Karsten Gnuschke
Partner
WTS Group
Germany
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The WTS Global Board: Driving continuous improvement and growth
Stefan Hölzemann
Partner
WTS Group
Germany
Fritz Esterer Chairman of the Board
CEO
WTS Group
Germany
Bernard Peeters
Partner
Tiberghien
Belgium
Luis Rogerio Farinelli
Partner
Machado Associados
Brazil
Edward Mwachinga
Partner and Co-Founder
Viva Africa Consulting
Kenya
Magdalena Saja
Partner and Founder
WTS & SAJA
Poland
Shanker Iyer
Partner and Founder
Iyer Practice
Singapore
Rakesh Dharawat
Partner
Dhruva Advisors
India
9 directors from 4 continents
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The WTS Global Management Team: Focusing on quality, global coordination and development
Karsten GnuschkeGlobal Coordinator
Marie Christin Shenouda Business
Development
Ute Lehmann QPRM
Thomas MelcherLegal
Alexa WirtzBusiness
Development
Kelly MgborQPRM & Business
Development
20+ years operational tax experience
Sarah ChailliéBusiness
Development
Wim Wuyts CEO
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Our Quality, Process & Risk Management (QPRM) approach: Ensuring highest standards worldwide
QPRM
Effective tools &
processes
Integrity
as guiding
principle
Board
approval of
new network
partners
Central and
regional
QPRM teams
» Quality handbook
» Centralized compliance check
» Detailed questionnaires
» Regular onsite reviews for new and existing member firms
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Our regional coordinators: Enforcing coherence across the world
Karsten GnuschkeWestern Europe
Beverly PacanskyAmericas
Zoltán LambertCentral and Eastern
Europe
Shanker ÍyerAsia Pacific
Edward MwachingaAfrica
Regional tasks
» Win new network partners in the region
» Implement QPRM reviews
» Conduct regular service line meetings
» Promote joint marketing activities
» Enforce WTS Global brand
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Collaborating from network to network: WTS Global and LATAXNET
Argentina • Rosso Alba, Francia & Asociados
Bolivia • Guevara & Gutierrez S.C.
Brazil • Machado Associados
Chile • EGB Espinosa Granese Bianchi Abogados
Colombia • Lewin & Wills – L&W
Costa Rica • Facio & Cañas
Dominican Republic • De Castro, Rivas & Rodriguez
Ecuador • Legal Advisors
El Salvador • Romero Pineda & Asociados
Guatemala • Mayora & Mayora
Honduras • Gufa Law
Mexico • Turanzas, Bravo & Ambrosi
Nicaragua • Alvarado & Asociados
Panama • Rivera, Bolivar & Castañedas
Paraguay • Ferrere Abogados
Peru • Rubio Leguia Normand & Asociados
Uruguay • Ferrere Abogados
Venezuela • Torres, Plaz & Araujo – TPA
Comprehensive tax and legal service capabilities in 18 Latin American countries
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Redefining global tax consulting
» World leading tax expertise
» No audit, free of conflict
» Award-winning, passionate partners
» Innovative, pragmatic solutions
» Trusted quality
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We are looking forward to working with you!