pwc’s customer & investor tax transparency (citt) compare tool · assigned package. a similar...
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PwC’s Customer & Investor Tax Transparency (CITT) Compare Tool
An automated solution for managing global tax information exchange requirements surrounding FATCA, UK FATCA and CRS
www.pwc.com
November 2015
Various Sources of Information
• Given the various sources of primary information, from the IRS, US Treasury, OECD and local regulatory authorities, clients are looking for a repository of such information in order to centralizes searches.
• The CITT Compare Tool will house active links to relevant primary documentation, including the U.S. regulations, Annexes maintained by the OECD, EU Directives as well as local regulation and guidance.
Different Users with Varying needs
• Financial institutions are impacted in multiple areas of their operations by Customer & Investor Tax Transparency initiatives. These units / functions have different needs and require a flexible solution.
• Compare Tool provides users with standardized overviews and the option to create individualized reports which can be saved to the user’s profile, giving users the freedom to tailor their searches based on individual needs.
Frequent Regulatory Change
• Frequent regulatory changes have become a constant within the area of Customer & Investor Tax Transparency. Managing these changes from various sources (IRS, OECD, EU and local authorities has become a significant task.
• Based on a 2-step alert process, users will be made aware of regulatory changes in an efficient manner and also be notified when the Compare Tool is updated to reflect these changes, allowing for new searches to be run and stakeholders to be notified of impacts to their institutions.
PwC’s CITT Compare Tool was designed to address a number of challenges that our clients with global operations face in complying with tax information exchange and tax transparency initiatives around the world.
Our holistic service offering: PwC has developed a suite of CITT Tools to address critical compliance needs
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Our solution includes end-to-end assistance with development of internal controls, facilitation of educational workshops and
development of remediation plans, including back-office solutions
In an area where the only constant is change, the CITT Compare Tool strives to address the three areas
which clients find most challenging to manage within their global operations.
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PwC’s CITT WebpageCentral Hub for CITT Updates & Tools
How the CITT Compare Tool achieves these results
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The user will be asked to select a “base country” when using the tool. This is
the country against which differences should be compared. By doing so, all
reports will be presented in comparison to the selected “base country” and
differences will be clearly highlighted.
A variety of reports can be generated from the CITT Compare Tool in differing formats. The user will be able to
select pre-determined overviews highlighting the areas of Status, Reporting and Withholding,
containing the criteria relevant for each topic.
The user will also be able to Create own report where the user is free to not only select a baseline country
and countries for comparison, but also any, or all, of the over 200 criteria covering FATCA, UK FATCA
and CRS within the Compare Tool. Each user will have the ability to save these reports within his/her profile
and re-run the reports as required based on regulatory changes in the selected countries.
PwC will provide alerts to users in a 2-step process: First, the user will be notified of any regulatory
changes in any jurisdiction, i.e. the passage of local legislation via the CITT Blog (which feeds into the CITT
Compare Tool). Once the Compare Tool has been updated to reflect the change, the user will be notified again.
By selecting your base country, you are telling the CITT Compare Tool what the regulatory baseline is for comparison purposes. Results for this country will be included in any reports that are run and differences from the base country will be highlighted.
Here the user will select the countries to be compared to the base country. For example, a user responsible for EMEA could select all locations where his/her institution has operations in EMEA to compare against the base country.
A variety of overviews and reports are available
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The Executive Report is
intended to give readers an
overview of the regulatory and
operational environment in
each jurisdiction with regard to
Customer & Investor Tax
Transparency. This could act as internal status updates, a tool
for on-boarding team members or communication
to steering committees.
The Reporting Overview will highlight the
statutory deadlines in a timeline for all
selected countries (including automatic
extensions). Details will be provided for each country including the format and channel for reporting as
well as content for reporting for each year.
The Status Overview is intended to
highlight the regulatory
status in each selected
jurisdiction. This will
include the legislative status of
FATCA / UK FATCA and CRS, links to
primary documents,
enactment and enforcement
dates as well as other related
criteria.
The Executive Report will be generated in a booklet format including general information on Customer & Investor Tax Transparency, as well as country-specific details under the headings of:
• Implementation• Governance & Compliance• Due Diligence
• Reporting• Withholding• Penalties
Users will also be able to select the specific
criteria to be compared
through the “Create your own Report” functionality.
In this case the users are free to select from nearly 200 criteria
along the categories of
Governance & Compliance, Scope, Due Diligence,
Reporting and Withholding.
The Global Voluntary Disclosure Program Overview provides a
comparison of various voluntary
disclosure initiatives as well as consequences for a taxpayer
who has committed tax evasion and is detected by the tax authorities without having made a timely
and comprehensive
voluntary disclosure.
The status overview provides a view on the user’s regulatory environment
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The Status Overview opens by
highlighting the regulatory
environment for FATCA and UK
FATCA based on the IGA status and
relevance of UK FATCA for all
jurisdictions in the assigned package.
A similar overview is provided for the
Common Reporting
Standard based on the latest
information from the OECD and the
individual countries around
the world.
In addition, a graphical
overview is provided to
indicate the status. This view will
change by clicking between the “FATCA/UK
FATCA” and “CRS View”.
By clicking on “Next”, the user will be provided with a tabular
comparison on the status in each
location, including links to the latest
regulatory guidance, effective
dates of the regulations and
other similar information.
The reporting overview provides a view on the reporting timeline and requirements in each country
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The Reporting Overview opens by
highlighting the reporting
deadlines for FATCA and UK
FATCA based on the IGA status and
relevance of UK FATCA for all
jurisdictions in the assigned package.
A similar overview is provided for the
Common Reporting
Standard based on the latest
information in each country.
In addition, a graphical
overview is provided to indicate the reporting
deadlines in each country. This view
will change by clicking between the “FATCA/UK
FATCA Reporting” and “CRS
ReportingView”.
By clicking on “Switch to
Timeline View”, the user will be provided with a
graphical overview of the
reporting deadline(s) in each
jurisdiction
The global voluntary disclosure program overview provides information of various voluntary disclosure initiatives and consequences of tax evasion
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The Global Voluntary Disclosure Program
Overview opens by highlighting the
status of voluntary disclosure program.
A similar overview is provided for
special voluntary disclosure program. Different
jurisdictions are shaded differently
depending on whether they have (or recently had) special voluntary
disclosure programs.
In addition, a graphical overview
is provided to indicate the status
of each country. This view will
change by clicking between the “Voluntary disclosure
program” and “Special voluntary
disclosure program”.
By clicking on “Create PDF”, the
user will be provided with a PFD file for the user’s currently
selected overview of the status of
global voluntary disclosure program.
Users are able to create their own reports, allowing them to tailor their reports to specific needs
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The Create Your Own Report allows the user to select from all available criteria to create a tailored report intended to fit the user’s specific needs. These criteria are categorized for easy navigating.
By clicking on the toggles, the user will see all criteria within that specific category and may begin selecting some, or all, of the criteria to tailor his/her report.
Users are able to check the AEoI updates taking place across jurisdictions
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The news section allows the users to get acquainted with the AEoI updates taking place in all jurisdiction (not just those within a particular client module).
Users may click on any of the news headlines in order to be redirected to the CITT News Blog where more information can be found.
Please contact PwC to learn more about how the Compare Tool can help you navigate through CITT compliance
Dr. Karl Küpper
Partner, Germany
+49 69 9585 5708
Mark D. Orlic
Director, Germany
+49 69 9585 5038
© 2015 PricewaterhouseCoopers Aktiengesellschaft Wirtschaftsprüfungsgesellschaft.All rights reserved. In this document, “PwC” refers to PricewaterhouseCoopers Aktiengesellschaft Wirtschaftsprüfungsgesellschaft, which is a member firm of PricewaterhouseCoopers International Limited (PwCIL). Each member firm of PwCIL is a separate and independent legal entity.
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