Transcript Global pressure in taxation policy

Global pressure in taxation
policy
Jiri Nekovar
President of CFE
Global efforts to recover taxes
• The exchange of information between tax administrations
– 119 countries – activity of OECD
• Anti-money laundering act – activity of OECD
• Base Erosion and Profit Shifting – activity of OECD / G-20
• Aggressive tax planning – activity of EU
• Taxation of savings – activity of EU
• FATCA – activity of the U.S.A. with a global impact
• Inconsistency in definitions of intangible assets between
UN and OECD in relation to “transfer pricing” and new
activities of BRIC
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BEPS – Action plan of OECD
Action 1 Address the
Tax
Challenges
of the
Digital
Economy
Action 8 Assure that
Transfer
Pricing
Outcomes
are in Line
With Value
Creation/
Intangibles
Action 2 Neutralise the
Effects of
Hybrid
Mismatch
Arrangements
Action 9 Assure that
Transfer
Pricing
Outcomes
are in Line
With Value
Creation/
Risks and
Capital
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Action 3 Strengthen
CFC Rules
Action 10 Assure that
Transfer
Pricing
Outcomes
are in Line
With Value
Creation/
Other HighRisk
Transactions
Action 4 Limit Base
Erosion via
Interest
Deductions
and Other
Financial
Payments
Action 5 Counter Harmful
Tax Practices
More Effectively,
Taking into
Account
Transparency
and Substance
Action 12 Require
Action 11Taxpayers to
Establish
Methodologi Disclose Their
es to Collect Aggressive
and Analyze Tax Planning
Data on BEPS Arrangement
s
and the
Actions to
Address It
Global pressure in taxation policy
Jiri Nekovar
Action 7 Prevent the
Artificial
Avoidance
of PE Status
Action 6 Prevent
Treaty
Abuse
Action 13 –
Action 15
Develop a
Action 14 Make Dispute Multilatera
l
Resolution
Mechanisms Instrument
More Effective
Re-examine
Transfer
Pricing
Documentation
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BEPS – Foreign direct investment
• 2010: 5.11 % of global foreign direct investment (FDI) points
to Barbados, Bermuda and the British Virgin Islands (Germany
4.77 %, Japan 3.76 %)
• The British Virgin Islands is the second largest investor to
China, where it brought 14 % of all FDI (Hong Kong 45 %,
USA 4 %)
• The largest foreign direct investors to Russia – Cyprus (28 %),
British Virgin Islands, Bermuda and Bahamas
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Countries struggle to attract foreign investment
Foreign investment as of the end of 2012 in the Netherlands and
Luxembourg amounted to USD 5.8 tn - More than in the U.S.A.,
UK and Germany in total.
According to OECD, the Netherlands accumulated foreign
investment amounting to USD 3.5 tn, but only USD 573 bn
ended in the “genuine” Dutch economy.
The G–8 and G-20 countries have put taxes on the first place in
their agendas.
Starbucks, Amazon, Google in the United Kingdom and Apple in
the U.S.A. pay little in taxes by the parliamentary committee.
https://docs.google.com/file/d/0B2ps1bX4Rc0zdkZlQlVMQzY4VW8/edit?usp=sharing
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G-20 vs. OECD
G-20
OECD
• 85 % of global GDP
• 65 % of global GDP
• Over 75 % of global trade
• About 63 % of global trade
• 2/3 of world population
• 20 % of world population
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G-20
Countries of OECD
Non-OECD countries
GDP per
capita
(USD)
Share in the
world trade
(% GDP)
Saudi Arabia
31,800
56.2
51.8
Russia
22,408
29.4
18,288
33.0
South Africa
10,798
28.3
United Kingdom
37,446
31.6
Republic of China
9,095
27.3
Canada
41,559
30.4
Indonesia
4,344
24.6
Italy
33,140
30.2
India
3,900
23.8
France
36,249
27.4
Argentina
18,400
19.7
Turkey
18,114
26.4
Brazil
12,100
12.6
Australia
45,016
19.9
Japan
35,190
14.7
USA
51,689
13.5
GDP per
capita (USD)
Share in the
world trade
(% GDP)
South Korea
30,800
56.5
Germany
41,231
Mexico
Country
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Country
Global pressure in taxation policy
Jiri Nekovar
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G-20
 Countries of OECD
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 Countries of EU
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 Non-OECD countries
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St. Petersburg - September 2013
• Globalization in taxes
– Globalization in tax consultancy
• G-20 – Base Erosion and Profit Shifting
• CFE General Assembly with participation of
representatives of AOTCA and WAUTI
• Adoption of the idea of The Global Tax Advisers
Co-operation Forum
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Self-regulating organizations in the world
• Confédération Fiscale
Européenne
• 25 countries of Europe
www.cfe-eutax.org
www.aotca.org
• Asia Oceania Tax
Consultant’s Association
• 19 countries of the Asia
and Oceania Region
• West African Union of
Tax Institutes
• 15 countries of West
Africa
www.wauti.org
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Conclusion
 Rights of taxpayers and the Taxpayer Charter model
 Result of the CFE – AOCTA – STEP cooperation – participation of
35 countries
 Invitation to WAUTI to take part in the Taxpayer Charter project
 Paying taxes is not an issue of morality, it is an issue of adherence
to high-quality tax legislation
 The tax advisers’ task is to help clients to comply with the laws
 The role of countries is to create high-quality tax laws and to take
part in a rational arrangement of taxation in the world
 To send the best tax advisers to workgroups of The Global Tax
Advisers Co-operation Forum
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Thank you for your attention!