european fiscal services ltdian.hayes@e-fisc.com

The Future of Tax Practice BKR Worldwide Meeting

Dublin, Ireland 2013

European Fiscal Services Ltd ian.hayes@e-fisc.com

The Future of Tax Practice 2013

Ian E Hayes FCA FIIT CTA FRSAVice President C.F.E.

Consultant Tax Adviser

European Fiscal Services Ltd ian.hayes@e-fisc.com

European Fiscal Services Ltd ian.hayes@e-fisc.com

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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

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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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2001 -2013 -

ECONOMIC CRASH

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

October 2013

European Fiscal Services Ltd ian.hayes@e-fisc.com 19

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Thank you! Food for thought?

October 2013