the future of tax practice bkr worldwide meeting dublin , ireland 2013

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The Future of Tax Practice BKR Worldwide Meeting Dublin, Ireland 2013 European Fiscal Services Ltd [email protected]

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The Future of Tax Practice BKR Worldwide Meeting Dublin , Ireland 2013. European Fiscal Services Ltd. i [email protected]. The Future of Tax Practice 2013. Ian E Hayes FCA FIIT CTA FRSA Vice President C.F.E. Consultant Tax Adviser. European Fiscal Services Ltd. - PowerPoint PPT Presentation

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Page 1: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

The Future of Tax Practice BKR Worldwide Meeting

Dublin, Ireland 2013

European Fiscal Services Ltd [email protected]

Page 2: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

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]

Page 3: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

3

Our Time Today

Highlights of the millennium years Current Drivers The Next 2 years Tax Practice of the future Discussion points

October 2013

Page 4: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

4

2001 -2013 - 1

Client Relations Software developments

› Professional› State sponsored

Old methods new problems Pressure on fees

October 2013

Page 5: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

5

2001 -2013 - 2

Anti Money laundering Regulation and Competition Tax Avoidance/Abuse

› Ethics› Client expectation› State reaction

The need to invest

October 2013

Page 6: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

6

2001 -2013 -

ECONOMIC CRASH

October 2013

Page 7: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

7

Current Drivers - 1

G8 to G20 Revenue Authorities OECD Tax Activists and NFPs Highly visible corporate planning The Politics of tax havens

October 2013

Page 8: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

8

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

Page 9: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

9

Current Drivers - 3› The search for

Transparency Consistency Certainty

› Tax “fairness”

October 2013

Page 10: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

10

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

Page 11: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

11

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

Page 12: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

12

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

Page 13: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

13

The Global Tax Forum

Automatic bilateral exchange of information

October 2013

Page 14: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

14

Tax Practice in the Future – 1 Bread and butter issues

Compliance Risk management

› Client› Authority› Staff

Tax in a changing environment

October 2013

Page 15: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

15

Tax Practice in the Future – 2 Expenditure and Investment

Training Software Practice assured

October 2013

Page 16: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

16

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

Page 17: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

17

Tax Practice in the Future – 4 Sandwich filling?

Forensic Recovery Restoration Support through litigation Untying the knots Cross border transactions New Taxes

October 2013

Page 18: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected]

18

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

Page 19: The  Future of Tax Practice  BKR  Worldwide  Meeting Dublin ,  Ireland  2013

European Fiscal Services Ltd [email protected] 19

THE FUTURE OF TAX PRACTICE

Thank you! Food for thought?October 2013