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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 Ghana February 2014 Global pressure in taxation policy Jiri Nekovar 2 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 Ghana February 2014 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 3 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 Ghana February 2014 Global pressure in taxation policy Jiri Nekovar 4 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 Ghana February 2014 Global pressure in taxation policy Jiri Nekovar 5 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 Ghana February 2014 Global pressure in taxation policy Jiri Nekovar 6 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 Ghana February 2014 Country Global pressure in taxation policy Jiri Nekovar 7 G-20 Countries of OECD Ghana February 2014 Countries of EU Global pressure in taxation policy Jiri Nekovar Non-OECD countries 8 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 Ghana February 2014 Global pressure in taxation policy Jiri Nekovar 9 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 Ghana February 2014 Global pressure in taxation policy Jiri Nekovar 10 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 Ghana February 2014 Global pressure in taxation policy Jiri Nekovar 11 Thank you for your attention!