ISSUES AND CHALLENGES FACING TAX ADMINISTRATIONSThe perspective of Tax Administrations

EU Commission – DG TAXUD – Morgan Guillou14 April 2015

1. Existing practical tools Automatic exchange of information (AEOI)• EU experience and evolution over recent years

• MAD: EU Mutual Assistance Directive • Adoption: 1977 – Application: 1979

• EUSD: EU Savings Directive• Proposal: 2001 – Adoption: 2003 – Application: 2005 • Adoption revision: 2014 – Application revision: 2017

• DAC1: EU Directive on Administrative Cooperation 1• Proposal: 2009 – Adoption: 2011 – Application: 2015• Content: available information on income from employment, director’s fees,

immovable property, pensions, life insurance products• DAC2: EU Directive on Administrative Cooperation 2

• Proposal: 2014 – Adopted: 2014 – To be applied: 2017/2018• Content: interest, dividends, capital gains, account balances …

• DAC3: EU Directive on Administrative Cooperation 3• Proposal: March 2015 • Content: tax transparency package (rulings)

2Operating Transfer Pricing rules in the New Transparent Environment: Exploiting the Potential of New Technologies – Vienna 13-14 April 2015

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1. Existing practical toolsAutomatic exchange of information (AEOI)• 4 basic but very different tax activities

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1. Tax collection and treatment

2. Request for information

3. Automatic exchange of information

4. Matching and use of information received

from AEOI

Operating Transfer Pricing rules in the New Transparent Environment: Exploiting the Potential of New Technologies – Vienna 13-14 April 2015

1. Existing practical tools Focus on tax transparency package

4Operating Transfer Pricing rules in the New Transparent Environment: Exploiting the Potential of New Technologies – Vienna 13-14 April 2015

1. Existing practical tools Focus on tax transparency package

5Operating Transfer Pricing rules in the New Transparent Environment: Exploiting the Potential of New Technologies – Vienna 13-14 April 2015

1. Existing practical tools Focus on Country by Country Reporting• 2013: EU Heads of State agreed to CbCR for tax

purposes at the special summit on tax evasion• Current state of play:

• CRD IV – Credit institutions & investment firms• Extractive and forest industries

• What's coming next?

Operating Transfer Pricing rules in the New Transparent Environment: Exploiting the Potential of New Technologies – Vienna 13-14 April 2015 6

2. Future steps • Transparency Package• EU Transfer pricing framework

• Improving existing EU instruments and standards ; developing new ones

• Facilitate implementation and support Member States in this respect

• Focus on simplification, clarification and fiscal consolidation

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