OECD Common Reporting Standard (CRS ... · Data transmission format (CRS XML Schema) & data...

OECD Common Reporting Standard (CRS) implementation in Latvia

17.12.2014.

www.pwc.com

Jana Orlova, PwC Legal Latvia

Liene Skrodere, PwC Germany

PricewaterhouseCoopers SIA

Agenda

1 What is CRS and what is its aim?

2 What is the aim of the EU Directive on Administrative Cooperation (DAC) and how does it affect financial institutions?

3 What is the difference between CRS and FATCA and how will CRS affect the operations of financial institutions?

4 Most notable risks, challenges and solutions of implementing CRS

Agenda

Slide 2

17.12.2014. OECD Common Reporting Standard (CRS)


What is CRS? What is its aim?

Slide 3



CRS has become a widely-discussed topic on the news internationally

Slide 4



Banking industry’s secrets are coming to an end…

Bretton Woods (set up post war

financial construct including exchange controls)

1944

Generally only the very wealthy made any significant use

of private tax havens

1945 - 1970

Exchange controls start to be

abolished, leading to enormous

capital flows into "offshore /

international" financial centres

1970

OECD "Harmful tax competition an

emerging global issue" is published

1998

Capital in and use of international financial centres

expands exponentially

1970 - 1998

EU Savings Directive. First

multilateral attempt to end

banking secrecy

2002

Financial crisis leading to a

political backlash

against "tax cheats"

2008

UBS indicted for assisting

with tax evasion for U.S.

citizens

2007

2013

Voluntary disclosure regime

launched by Department of

Justice

2012

FATCA legislation passed

2017

Start of global automatic

exchange of customer

information

2014

Implemen-tation of FATCA

2014 51 countries sign up for automatic


information

Slide 5



Banking industry’s secrets are coming to an end…

FATCA Model 1 IGA includes

commitment to develop a

common model

June ‘12

In Los Cabos, G20 welcomes OECD report on AEOI

July ‘12

G20 Support

AEOI

Nov ‘12

OECD report to G8 on common model for AEOI

June ‘13

G5 pilot (early

adopters)

Apr ‘13

G20 endorse AEOI as new

global standard and ask OECD to develop CRS

Sep ‘13

European Council

commits to adopt DAC2 in

2014

Dec ‘13

GFTEI creates AEOI group

Nov ‘13

Feb ‘14

G20 endorse

CRS

Jan ‘14

OECD approves

first part of standard

Nov ‘14

Full version of CRS presented to

G20 Leaders

Oct ‘14

Ecofin political agreement on revised DAC2

Oct ‘14

51 countries sign up for automatic


information

Mar ‘14

Early adopters

statement (44

countries)

OECD Ministerial Declaration

May ‘14

Jun ‘14

OECD approves full

version of standard

Jul ‘14

OECD Council Recommend.

on AEOI

Sep ‘14

Full version of CRS endorsed

by G20 Ministers

Slide 6



The new tax transparency is covering both, customer and on-balance taxation

Slide 7



• OECD: The Organisation for Economic Co-operation and Development

• CRS: Common Reporting Standard

• Purpose: combatting tax evasion

• Start: 1 January 2016

• Affected entities: Financial institutions

• Data to be exchanged: Financial account information

• Affected clients: Reportable persons

What is OECD CRS?

Slide 8



CRS - overview of key process


Slide 9

What to report

When to report

• Basic account information including place of birth if local law already requires it to be obtained and reported

• Certain payments and gross proceeds

• FI date: 2017 but exact date to be provided in local guidance

• Exchange date between Governments: Annually from 2017

Who to report

on

Reportable Accounts held by: • Reportable person(s); or • Passive NFE’s with one or more controlling

person(s) who are reportable persons

Reporting FIs will report the data to local authorities annually, who will automatically exchange the

information with the other participating jurisdictions. The CRS reporting schema will be used by

Governments to exchange the information and may also be used by Reporting FI’s but this will be

dependent on local jurisdiction guidelines.

How to report

Verify

Ready

• Confirm the reasonableness of self-certification on the basis of AML/KYC information and relationship manager’s knowledge

• Monitor for change in circumstances

• Account aggregation • Generating report

Gather

Information to acquire from new client: • Identification information • Tax identification number (TIN) • Tax residency jurisdiction


Within CRS term «Financial Institution» denotes a Custodial Institution, a Depository Institution, and Investment Entity, or a Specified Insurance Company

Financial institution Respective institutions

Custodial institution – any Entity that holds, as a substantial portion of its business, Financial Assets for the account of others.

• Banks • Brokers • Pension funds • Payment institutions • Asset managers • Life insurance companies

Depository institution – any Entity that accepts deposits in the ordinary course of a banking or similar business.

Investment entity – any Entity that that primarily conducts as a business one or more of the following activities:

• Trading in money market instruments; • Individual and collective portfolio management; • Otherwise investing, administering, or managing

Financial Assets or money on behalf of other persons;

Specified Insurance Company – any Entity that is an insurance company (or the holding company of an insurance company) that issues, or is obligated to make payments with respect to, a Cash Value Insurance Contract or an Annuity Contract.

Slide 10



What is meant with «Financial account»?

Financial account Respective product

Financial account – an account maintained by a Financial Institution, and includes: • a Depository Account, • a Custodial Account, • any equity or debt interest in the Financial

Institution, • any equity or debt interest in the Financial

Institution, if the class of interests was established with a purpose of avoiding reporting,

• any Cash Value* Insurance Contract, • any Annuity Contract issued or maintained

by a Financial Institution other than a noninvestment-linked, non-transferable immediate life annuity.

• Bank savings, deposit, securities accounts

• Brokers – financial instrument/ securities accounts

• Payment institutions – accounts where client funds are held

• Asset managers – accounts where client funds are held under individual portfolio management, investment fund certificates

• Life insurance – life insurance contracts

• Pension funds – pension fund certificates

* Cash value – the greater of (i) the amount that the policyholder is entitled to receive upon surrender or termination of the contract (determined without reduction for any surrender charge or policy loan), and (ii) the amount the policyholder can borrow under or with regard to the contract.

Slide 11



OECD CRS principles From OECD presentation at European Customer and Investor Tax Transparency Conference (Frankfurt, 3 – 4 November 2014), by Philip Kerfs

Common Reporting Standard (CRS) • Defines reporting and due diligence rules for financial institutions. • To be translated into domestic law by participating jurisdictions. • Based on FATCA, to leverage investments made by financial institutions and governments,

with some amendments to remove US specificities and take into account multilateral context.

Model Competent Authority Agreement (Model CAA) • To activate the exchange of information collected under the CRS. • To be used in combination with any underlying legal instrument permitting AEOI (e.g. Article

26 of the OECD Model Tax Convention or Article 6 of MAAC).

Commentaries on CRS and Model CAA • To ensure consistent implementation and equal level playing field.

Data transmission format (CRS XML Schema) & data transmission and encryption standards

• CRS XML scheme for exchange under CRS was built in parallel with FATCA XML schema to maximise consistency.

Slide 12



CRS: Building on FATCA, EU Savings Directive and FATF to have Single Standard and Reduce Cost From OECD presentation at European Customer and Investor Tax Transparency Conference (Frankfurt, 3 – 4 November 2014), by Philip Kerfs

• Personal data: name, address, tax residence, TIN • Financial data: account balance, investment income, sales proceeds from

financial assets

Similar scope of information reported

• Banks, custodians, insurance companies and investment entities (e.g. certain collective investment vehicles)

Similar scope of financial institutions required to report

• Individuals • Entities (including trusts and foundations) • Controlling persons (i.e., beneficial owners) of entities

Similar scope of account holders subject to reporting

• Distinction pre-existing /new, individual/entity, lower value/high value accounts

Similar Due diligence procedures

Slide 13



Next steps for OECD From OECD presentation at European Customer and Investor Tax Transparency Conference (Frankfurt, 3 – 4 November 2014), by Philip Kerfs

• Ongoing maintenance to resolve issues and ensure consistency (in consultation with FIs).

• Produce training material (CRS Implementation Handbook) and co-host training events for implementing countries (together with Global Forum).

• CRS portal for both general and country-specific information on implementing the Standard (including information on TINs and residence rules).

• Continued support to « operationalise » Multilateral CAA.

• Voluntary disclosure

• Toolbox for making effective use of information.

• Alignment of TRACE to CRS and assist in country implementation.

Slide 14



Next Steps for Country implementation From OECD presentation at European Customer and Investor Tax Transparency Conference (Frankfurt, 3 – 4 November 2014), by Philip Kerfs

• Translating the reporting and due-diligence rules into domestic law

• Selecting a legal basis for the exchange of information

• Entering into Competent Authority Agreements

• Protecting confidentiality and safeguarding data

• Making effective use of the information

• Putting in place the related administrative resources and required IT infrastructure

• Developing secure, effective and common transmission systems

• Measuring impact

• Voluntary disclosure initiatives

Slide 15




Slide 16

OECD CRS expected account due diligence and reporting timeline including the revised DAC

Dec 2015

Expectation that EU Member

States adopted the revised DAC

Dec 2014 EU legislation expected to encompass the CRS

2018 2017 2016 2015 2014

Political Milestones

Account Due Diligence

Reporting

2013

Apr 19, 2013 G20 countries mandate the OECD to develop the Common Reporting Standard (CRS)

Jul 21, 2014 Release of final CRS/

CAA, Commentary and XML data

schema

Sep, 2014 •OECD formally presents the CRS to G20 finance ministers (endorsement) •EU Commission proposes amendment of the DAC, which shall also include the CRS

Dec 31, 2015 Cut-off date for pre-

existing accounts; eventually already collecting account

balances or other data

Jan 01, 2016 New account opening procedures in place

Dec 31, 2016 Due diligence

procedures must be completed for pre-existing high value

accounts

Dec 31, 2017 Due diligence

procedures must be completed for all other pre-existing accounts.

Sep 30, 2017

Initial automated ex-change of new

accounts and pre-existing high value

accounts excl. gross proceeds between

governments

Sep 30, 2018 Reporting shall

include all (low and high value) reportable

accounts and gross proceeds between

governments

Jan 01, 2016 Anticipated “Big Bang” start date for “Early Adopter” countries. All 28 EU Member States have committed as Early Adopters to implementation of revised DAC1

31 July 2015 EU publishes list of entities / accounts treated as non-reporting or excluded Oct 2014

•OECD Global Forum conference in Berlin including a signing

ceremony regarding CRS agreements

•ECOFIN approves adapting the DAC to include the CRS

OECD CRS Milestone Revised DAC Milestone 1In the case of Reporting Financial Institutions located in Austria, all references may be delayed by

one year

Phasing-in of other countries

Fast approaching deadline!


CRS and IGA status across Jurisdictions - as of 10 December 2014

Signed

CRS Early Adopters New Procedures 2016 Reporting 2017

CRS Committed New Procedures 2017 Reporting 2018

CRS Committed Timeline TBD

Non-CRS

Sig

ned

IG

A

• Barbados • Belgium • Bermuda • British Virgin Islands • Bulgaria • Cayman Islands • Chile • Cyprus • Czech Republic • Denmark • Estonia • Finland • France • Germany • Gibraltar • Guernsey • Hungary • Ireland • Isle of Man

• Italy • Jersey • Latvia • Liechtenstein • Lithuania • Luxembourg • Malta • Mauritius • Mexico • Netherlands • Norway • Poland • Slovenia • South Africa • Spain • Sweden • Turks and Caicos

Islands • United Kingdom

• Austria • Australia • Bahamas • Brazil • Canada • Costa Rica • Japan • Hong Kong (China) • Israel • New Zealand • Singapore • Switzerland

(none) • Honduras • Jamaica • Moldova

Ag

reed

in

Su

bst

an

ce I

GA

• Anguilla • Colombia • Croatia • Curaçao • Dominica • Greece • Greenland • Iceland • India • Montserrat

• Portugal • Romania • San Marino • Seychelles • Slovak Republic • South Korea • Trinidad and Tobago

• Antigua and Barbuda

• China • Grenada • Indonesia • Macao • Malaysia • Qatar

• Saint Kitts and Nevis

• Saint Lucia • Saint Vincent

and Grenadines • Saudi Arabia • Turkey • United Arab

Emirates

• Bahrain • Panama

• Algeria • Angola • Armenia • Azerbaijan • Belarus • Cabo Verde • Cambodia • Dominican

Republic • Georgia • Guyana • Haiti • Holy See • Iraq • Kazakhstan

• Kosovo • Kuwait • Montenegro • Nicaragua • Paraguay • Peru • Philippines • Serbia • Taiwan • Thailand • Tunisia • Turkmenistan • Ukraine • Uzbekistan

No

n-I

GA

• Argentina • Faroe Islands

• Niue • Uruguay

• Albania • Andorra • Aruba • Belize • Brunei

• Marshall Islands • Monaco • Russia • Samoa • Sint Maarten

• Cook Islands • Nauru • Vanuatu

(all other jurisdictions)

Slide 17



Approach in other countries

Due to the tight deadlines little time is devoted to mutual coordination across participating countries and within the industry. There is a high probability for a diverging interpretation.

1. Consultations with the industry

2. Compliance assurance mechanisms: - New types of penalties; - Penalties for failing to provide a

declaration; - Penalties for systematic violations.

3. Cooperation among countries: - European Union; - Other countries.

Slide 18



What is the aim of the EU Directive on Administrative Cooperation (DAC) and how does it affect financial institutions?

Slide 19



EU DAC

Inclusion of CRS in EU legislation:

• Council Directive amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation;

• CRS text as Annex I;

• Annex II – separate explanatory rules from CRS commentaries;

• 31 December 2015 – implementation deadline;

• 1 January 2016 –National Laws coming into force;

• Austria receives one-year implementation relief.

Recital (13) In implementing this Directive, Member States should use the Commentaries on the Model Competent Authority Agreement and Common Reporting Standard developed by the OECD as a source of illustration of interpretation and in order to ensure consistency in application across Member States.

Slide 20



Impact on the activities of Financial Institutions

• Local lists of Non-Reporting Financial Institutions

• Entity that presents a low risk of being used to evade tax

• Procedure on new account opening applicable to new clients

• Pre-existing account – any Financial Account of a pre-existing client regardless of the date such account was opened (conditions apply)

• Cut-off dates for new clients/ pre-existing clients

• However, monitoring of changes in circumstances:

• Tax residency status; • account balances

(high/low value)

• Local list of Excluded Accounts

• Account that presents a low risk of being used to evade tax

Slide 21



CRS vs. FATCA

Slide 22



Expanded requirements under the CRS will result in significant implementation efforts in general

Slide 23



Variations in the definitions and scope under the CRS requires higher compliance efforts

Scope & Governance

The definition of a Financial Institution is broadly unchanged, however, subject to local implementation / variations

Not all definitions and types of Non-Reporting Financial Institution under the CRS correspond to the ones of the Model I IGA; certain Financial Institutions are in scope that are exempted under FATCA (e.g. local FIs)

Not clear how local legislator can exclude further “low risk entities and products”

Passive NFE definition widened: certain Investment Entities are in scope when located in a non-participating jurisdiction that would generally qualify as FIs under FATCA (deviating classification between FATCA and CRS)

No compliance and non-compliance concept for Financial Institutions

o No determination of an Expanded Affiliated Group (EAG) and limited FFIs/limited branches but for Related Entities

o No punitive taxation on NPFFIs

o Usage of GIIN or other identification numbers possible, no further registration of the Financial Institution

o No ongoing compliance certification towards competent authorities including an appointment of a Responsible Officer

o No documentation of FI status towards business partners / withholding agents

Tax authority approach to compliance yet to be determined

Allowance of 3rd Party Providers to fulfill reporting and due diligence requirements

Minor

Efforts

Significant

Efforts

Expected efforts

to implement into current operations

Slide 24



The number of clients to be reviewed will substantially increase under the CRS

Customer Due Diligence

General Account Due Diligence

Number of clients to be reviewed substantially increases

Threshold exemptions only exist for pre-existing entity accounts ($250,000) and not for individuals; distinction between low & high value accounts (> $1,000,000)

Focus on tax residency instead of citizenship

Removal of “regularly traded” exemption financial accounts definition – large potential impact on investment trusts, ETFs etc.

Deviating definition of a passive NFE in comparison to FATCA

Procedures required to (I) ensure a relationship manager identifies any change in circumstance and (II) enables a manual aggregation of accounts he knows or has reason to know

Simplified indicia check: place of birth omitted, standing instructions in conjunction with a deposit account are no longer an indicia

Preexisting Account Due Diligence

“Simplified” determination of a pre-existing client’s tax residency by residence address test based on current documentary evidence

If a pre-existing low value account becomes a high value account or a pre-existing entity account initially below $250,000 exceeds such value at the end of subsequent years, FI has a 1-year period to apply the due diligence procedures (IGA grants only 6 months)

New classification of “undocumented accounts” and revival of “dormant accounts”; annual enhanced review procedures

Annual re-application of relationship manager inquiry on high value accounts

New “Reasonable Efforts” procedure to retrieve a TIN or date of birth if missing

New Account Due Diligence

For new individual and entity accounts a self-certification is mandatory on account opening, if no other valid self-certification exists

Requirement to collect and maintain a TIN and date of birth for account holders of a reportable jurisdiction

Minor

Efforts

Significant

Efforts Expected efforts to

implement into current operations

Slide 25



Reporting

FIs should report to local authorities, who will exchange the data with partner jurisdictions

The number of partner jurisdictions with which to exchange information increased significantly

While CRS sets out data elements to be reported, jurisdictions may take the opportunity to request additional

information (wider approach, e.g., reporting may include domestic customers)

The CRS XML Data Scheme is conceptually based on the FATCA XML Data Schema, however, various

differences exist; additional data items: “place of birth” and “jurisdiction of residence”

Place of birth does not have to be reported if 1) it is not existing in the data of the FI 2) or it does not have to be

reported according to the respective partner country legislation (not a required item under FATCA)

TIN and date of birth not to be reported if 1) not existing in the data of the FI, and 2) are not required to be

collected according to domestic law

Gross proceeds must not be included in initial reporting (phasing-in possible; tbc in practice)

Controlling persons of passive NFEs that are located in a reportable jurisdiction have to be

reported, even when they are resident in the same reportable jurisdiction as the passive NFE

On closed accounts only the information of such closure needs to be reported (no balances)

Every tax residency has to be reported (multiple tax residencies = one file, multiple

addressees)

Balances and/or values of jointly held accounts shall be fully attributed to each of the

account holders

No transitional reporting regarding payments made to NPFFIs

Reporting will be more complex and burdensome due to the increased number of reportable jurisdictions

Minor

Efforts

Significant



Slide 26



The only relieved area – withholding is not required under the CRS

Withholding

No withholding on payments from certain income sources, including the identification and classification of withholdable payments, affected clients and business divisions

No payee-concept including a detailed analysis for special products (e.g. syndicated loans) or counterparties

Concept of non-participating financial institutions does not exist

No connection to the Qualified Intermediary regime including the determination of dividend equivalent payments (871(m))

Minor

Efforts

Significant



Slide 27



Expanded requirements under the CRS will result in significant implementation efforts in general

Customer Due Diligence

• Number of clients to be reviewed substantially increases (e.g. due to deletion of de-minimis-thresholds for individual clients)

• CRS focuses on tax residency, not citizenship

• Various due diligence procedures for pre-existing and new accounts exist; existing AML/KYC procedures may be used

• "Simplification" of indicia test

• New concept of "undocumented accounts" and revival of "dormant accounts"

• Requirement of "Reasonable Efforts"

Scope & Governance

• Though the definition of a Financial Institution is broadly unchanged, local deviations may apply

• Certain FIs exempted under FATCA (e.g. local FIs) are expected to be in scope

• Passive NFE definition widened to include certain Investment Entities

• No Responsible Officer concept foreseen

• Usage of GIIN possible

• Tax authority approach to compliance yet to be determined

Withholding

• There is no withholding under CRS

• No payee concept foreseen requiring a detailed analysis of products/payees

• Concept of non-participating institutions does not exist

• No interaction to the Qualified Intermediary regime including the provision of "Dividend Equivalent Payments" (871 (m))

Reporting

• FIs should report to local authorities, who will exchange the data with partner jurisdictions

• Reporting is expected to be based on FATCA data schema and elements, however, attributes may vary

• While CRS sets out data elements to be reported, jurisdictions may take the opportunity to request further information (“wider approach”)

CRS Efforts

FATCA Efforts

Slide 28



Implementation of FATCA and OECD CRS must run in parallel U

S F

AT

CA

2015 2016 2017

OE

CD

CR

S

30.09.2017:

First full reporting (reporting year 2016)

30.09.2016:

2nd year reporting additionally includes

payments to NPFFIs (reporting year 2015)

30.09.2015:

Initial reporting between governments

(reporting year 2014)

Basic account and account holder information


+ Certain income payments



+ Gross proceeds

30.09.2017:

Initial reporting between governments

(reporting year 2016; + data end of 2015)

30.09.2018:

First full reporting (reporting year 2017)





+ Gross proceeds

3 P

ha

ses

2 P

ha

ses

2018

New Account Opening Procedure must be in

place for “Early Adopter” countries

Slide 29



The indicia check was eased compared to the FATCA Model I IGA, however, the varying requirements need to be applied

# FATCA Model I IGA CRS

1. Identification of the account holder as a U.S. citizen or resident

Identification of the Account Holder as tax resident in a reportable jurisdiction

2. Unambiguous indication of a U.S. place of birth n/a

3. Current U.S. mailing or residence address (including a U.S. post office box or U.S. “in-care-of” address)

Current mailing or residence address (including a post office box, “in-care-of” or “hold mail” address) in a reportable jurisdiction

4. Current U.S. telephone number One or more telephone numbers in a reportable jurisdiction and no telephone number in the jurisdiction of the reporting FI

5.

Standing instruction to transfer funds to an account maintained in the U.S.

For accounts that are not Depository Accounts the Reporting Financial Institution must also review electronically searchable data maintained by them for standing instructions to transfer funds to an account maintained in a reportable jurisdiction

6. Current effective power of attorney or signatory authority granted to a person with a U.S. address

Currently effective power of attorney or signatory authority granted to a person with an address in a reportable jurisdiction

7. An ‘in care of’ or ‘hold mail’ address that is the sole address the FI holds for the account holder.

An ‘in care of’ or ‘hold mail’ address that is the sole address the Financial Institution holds for the account holder.

Slide 30



Challenges and solutions

Slide 31



Where do we find the greatest complexity within CRS as a result of global operations?

Regulatory Complexity

• Lack of alignment between IGAs now, could be worse under CRS

• Local laws require local expertise, which is a cost driver

• Incorporation of late adopters

• System of penalties

Data Management

• Difficulty implementing uniform processes for data collection

• CRS should impact all customers and local FIs

• Data privacy / security

Communication

• Disclosure to clients regarding reporting

• Internal communication

• Responding to tax / self-disclosure questions from clients

• Client on-boarding process

Reporting

• Various reporting channels

• Multiple reporting deadlines

• Difficulty in centralizing reporting function

Slide 32




Where do you see the biggest difficulties with implementing a response to CRS?

Source: Registration survey from European Customer and Investor Tax Transparency Conference (Frankfurt, 3 – 4 November 2014)

2%

5%

3%

5%

10%

12%

16%

47%

0% 10% 20% 30% 40% 50%

Other

Adhering to timelines

Legal Entity Analysis

Implementing reporting

Adjusting onboarding procedures

Due Diligence for pre-existing Ahs

Implementing a global compliance program

Understanding and coordination of local lawimplications

% of respondents

Slide 33




Where do you see the biggest relief in CRS as opposed to FATCA?

3%

3%

7%

12%

3%

22%

53%

0% 10% 20% 30% 40% 50% 60%

Other

Adhering to timelines

Due diligence for pre-existing account holders

Adjusting onboarding procedures

Implementing reporting

Implementing a global compliance program

No withholding

% of respondents

Slide 34


Source: Registration survey from European Customer and Investor Tax Transparency Conference (Frankfurt, 3 – 4 November 2014)


CITT Compare Tool PwC’s response to managing multinational complexity

1 Identifying the issues

2 Creating a solution

3 Demonstration of the CITT Compare Tool & CITT Gateway


Slide 35


What are the issues that financial institutions with global operations face?

Various Sources of Information - US Treasury - OECD - Local Authorities

Local Language

Different users with

varying needs

Frequent regulatory changes


Slide 36


Creating a solution for these issues requires coordination of a global network

Global Network

Up-to-date Information

Delivery Capabilities

IGAs are signed or considered to be in effect with over 100 countries

52 countries have already signed the CRS MCAA

Local laws will dictate implementation requirements

Global Network

The only constant within these projects is change

Alerts to users after information has been released & for system updates to reflect changes

CITT_Feedback e-mail address

Up-to-date information

Executive Report

Status Report

Standardized Reports

Create your own Report

Delivery capabilities


Slide 37


The PwC CITT Gateway and Compare Tools will help you navigating through multinational complexities…


Slide 38

141216_PwC CITT Gateway.ppsx



Closing Remarks

52 countries have signed the MCAA

Guidance will be coming soon, but timelines are still

tight

Global trends impact your

business models and shall drive your

response to regulation today

It is manageable but you should start

assessing impacts now

The new tax transparency is

pushing tax authority functions to financial services

industry

Thank you

This publication has been prepared for general guidance on matters of interest only, and does

not constitute professional advice. You should not act upon the information contained in this

publication without obtaining specific professional advice. No representation or warranty

(express or implied) is given as to the accuracy or completeness of the information contained

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members, employees and agents do not accept or assume any liability, responsibility or duty of

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information contained in this publication or for any decision based on it.

© 2014 PricewaterhouseCoopers SIA. All rights reserved. In this document, “PwC” refers to

PricewaterhouseCoopers SIA which is a member firm of PricewaterhouseCoopers

International Limited, each member firm of which is a separate legal entity.

Law Firm PricewaterhouseCoopers Legal Kr.Valdemara iela 21 Riga, LV-1010 Latvia T: +371 6709 4400 F: +371 6783 0055 [email protected]

JANA ORLOVA Senior Associate

PricewaterhouseCoopers Friedrich-Ebert-Anlage 35-37 60327, Frankfurt am Main Germany T: +49 69 9585 5035 F: +49 69 9585 1873 M: +49 151 1114 1769 [email protected]

LIENE SKRODERE Consultant

mailto:[email protected]








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