EU Mandatory disclosure regime —State of play and practical insights for financial services companies
12 September 2019
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... with you today
Raluca EnacheSenior Manager
KPMG’s EU Tax Centre
T: +31 88 909 1465
Paul FreemanDirector, Tax
KPMG in the UK
T:+44 (0) 20 7694 4121
Mark SemplePartner, Tax
KPMG in the UK
T:+44 (0) 20 7311 1850
Peter GrantPartner, Tax
KPMG in the UK
T: +44 20 76942296
Tony ManciniPartner, Tax
KPMG in the Channel Islands
T:+441481741845
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authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
Administration
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Topics for discussion
Agenda1 Local implementation state of play
2 UK developments
3 Channel Island & other 3rd countries
4 Draft KPMG DAC 6 software solution
5 Next steps
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DAC6 — state of play
DAC6 is adopted
Formal adoption by ECOFIN
DAC6 enters into force
MDR directive comes into force
State of play
3 countries have implemented the
rules
17 countries are discussing/in
process of approving draft legislation
Remaining 8: Draft bills expected
during the course of 2019
Automatic exchange
First exchange of information
between tax authorities
First deadline
Deadline to file retroactive information
May 25,
2018
June 25,
2018August 31,
2020
October 31,
2020Today
December
31, 2019
DAC6 becomes
effective
MDRs become applicable
Local implementation
Deadline for EU Member States
to implement DAC6 into local
law
July 1,
2020
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authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.6© 2019 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any
authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
EU-wide developments
European Commission
— Has published Implementation Regulation.
— Unique identification number to be
assigned to each reported arrangement.
— No further interpretation guidelines.
TAX3 Committee:
— Final report calls for reporting obligation to
be extended to purely domestic cases.
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authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
DAC6 implementation — the progress of implementation
1. Bulgaria
2. Ireland
3. Latvia
1. Belgium
(Draft legislation expected before
the end of the year)
2. Croatia
3. Greece
4. Malta
5. Romania
(Draft legislation expected autumn
2019)
1. Austria
2. Cyprus
3. Czech Republic
4. Denmark (public consultation
completed)
5. Estonia (public consultation
completed)
6. Finland (public consultation
completed)
7. France
8. Germany
9. Italy
10. Lithuania
11. Luxembourg
12. Netherlands (Draft legislation
published July 2019)
13. Portugal (Draft law subject to
public scrutiny)
14. Slovakia
15. Spain
16. Sweden
17. UK (public consultation deadline
October 11)
1. Poland (already applicable)
2. Slovenia (applicable as of July 1,
2020)
3. Hungary (applicable as of July 1,
2020)
No significant steps taken Draft legislation publishedDiscussions with
stakeholdersImplementation complete
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Local implementation — highlights
‘Vanilla’ implementation
closely following directive
Approach still to be
established
Expanded scope, e.g.
including domestic
arrangements,
additional taxes
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DAC6 implementation — penalties
0 200 400 600 800 1000 1200
Austria
Cyprus
Czech Republic
Denmark
Finland
France
Germany
Italy
Luxembourg
Netherlands
Portugal
Slovakia
Slovenia
Spain
Sweden
UK
Maximum penalty (EUR ‘000)
Penalty between EUR 30,000 and EUR 150,000
Penalty between EUR 150,000 and EUR 1.5 million
Penalty up to EUR 30,000
Penalty more than EUR 1.5 million
UK developments
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We are here!
12 February 2019
S 84 FA 2019 gives Treasury power to implement DAC 6 (and other international disclosure regimes) by regulation.
Implementation phase Applies
Disclosable arrangements where the first step in implementation takes place during the MDR implementation phase covered by ‘catch up’ reporting once regime becomes applicable.
31 December 2019
Deadline to implement MDR locally
22 July 2019
Draft UK legislation published for a consultation ending 11 October. Consultation document indicates current policy approach in a number of key areas, but full draft guidance not yet published.
31 October 2019
Brexit?
Where are we?
Consultation
31 January 2020
Brexit deferred?
1 July 2020
MDR ‘live’ reporting begins
UK election?
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authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
UK draft implementation : Reporting obligation— Reporting obligations sits with employer rather than employee.
— Person assessing the reporting obligation must take account of information which
they know or which is available to them. No need to do “significant extra due
diligence” or carry out a detailed trawl through all information held by an
organisation, but HMRC will challenge cases of wilful ignorance or deliberate
compartmentalising of key data.
— HMRC takes the view that finance providers can be intermediaries.
— “…the DAC is wider than the code of practice on taxation for banks, and so the fact
that a bank is compliant with the code will not, in and of itself, mean that a bank
has no obligations under the DAC. For example, arrangements which meet
hallmarks under Category D may not have any tax effect, and so would not
necessarily contravene the code of practice on taxation for banks.”
— Where legal professional privilege applies, non-privileged information (e.g. names
of relevant parties) must still be reported.
— Arrangement reference numbers will be assigned to reported arrangements and
may need to be referenced in tax returns.
Remember — policy still evolving and approach may change
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UK draft implementation : Branches
— Where do I report?
The consultation confirms that a non-UK resident company operating through a
UK branch should only need to report in the UK if there is no requirement in the
head office jurisdiction to report an arrangement the UK regards as disclosable.
— Is it cross-border?
The UK does not regard transactions between the UK branch and UK
counterparties as automatically meeting the “cross border” requirement to be
reportable. The UK view is that transactions must concern multiple jurisdictions
and those jurisdictions be of some “material relevance” to the transaction for it be
properly regarded as “cross border.”
Will UK approach be replicated by head office jurisdictions?
Non-UK
UK PE
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UK draft implementation : “Tax Advantage”— Why do ‘tax advantages’ matter?
Many hallmarks are only met if the main benefit test is satisfied — i.e. that the main
benefit or one of the main benefits which, having regard to all relevant facts and
circumstances, a person may reasonably expect to derive from an arrangement is the
obtaining of a tax advantage. No definition of “tax advantage” is given in the Directive.
— When does a relevant advantage arise?
The draft UK regulations adopt a broad definition of tax advantage, similar to that used
elsewhere in UK tax legislation, but subject to an important exclusion for cases which
can “reasonably be regarded as consistent with the principles on which the relevant
provisions that are relevant to the reportable cross-border arrangement are based and
the policy objectives of those provisions.”
— Which advantages are relevant?
Draft UK rules potentially apply to advantages relating to taxes equivalent to those
within DAC levied by any jurisdiction — i.e. not restricted to UK/EU tax advantages.
Reliance on carve out to exclude ‘acceptable’ planning/products
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UK draft implementation : Hallmarks
— Hallmark A(2) — no exclusion for ‘industry standard’ templates
— Hallmark B(2) — focus on ‘conversion’
— Hallmark C(1) — look through transparent entities
— Hallmark C(1) — ‘almost zero’ means less than 1%
— Hallmark C(1) — the relevant blacklist is the version in force when the reporting
obligation is being assessed
— Hallmark D — interpreted in line with OECD guidance
— Hallmark E — seeks disclosure of arrangements contrary to OECD TP
guidelines
UK interpretation of hallmarks given effect solely through guidance
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UK draft implementation : Penalties
— Compliance failures can attract penalties equivalent to those under the UK
DoTas regime: in most cases up to £600 per day or up to £1 million if
determined by the First-tier Tribunal.
— Penalties may be reduced in ‘special circumstances’ but these do not include
ability to pay or the fact that there is no overall loss of tax
— Penalties may be reduced where there is a ‘reasonable excuse’, but this
excludes:
- a lack of funds to take action;
- reliance on another person; and
- reliance on advice given or procured by an intermediary, based on
incomplete/inaccurate facts, or which reaches unreasonable conclusions.
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authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
Brexit impacts— The UK is currently due to leave the EU on 31 October 2019 – before the
deadline to implement DAC 6 – although this may be extended.
— The consultation on the draft UK implementation states that the UK will
“continue to apply international standards on tax aimed at tackling avoidance
and evasion” but falls short of explicitly stating that it would seek to implement
DAC 6 in its current form regardless of the eventual form of Brexit.
— Transitional arrangements have been proposed which would mean the UK
broadly remains subject to EU law until 31 December 2020 – after DAC 6 has
begun to apply. HMRC expects that these transitional arrangements will
require the UK to implement DAC 6, but it is unclear that those arrangements
will be adopted.
— It is possible that DAC 6 could be implemented even in the event of a “no
deal” Brexit, as DAC envisages third countries may opt in to some aspects,
but there is no official confirmation as to whether the UK would pursue this.
— Even in the event that DAC 6 is not fully implemented in the UK, there is likely
to be pressure for the UK to adopt the provisions of Hallmark D –
corresponding to the OECD’s recommendations on mandatory disclosure
regimes.
— Following any transition specific agreement is likely to be required to ensure
that exchanges of information under DAC 6 could continue.
— Absent any agreement will duplicate reporting under UK and EU regimes be
needed in some cases? What taxes will be covered?
Channel Islands & other 3rd countries
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Context
EU work on non-cooperative
jurisdictions Affected Jurisdictions Commitments Given
— Jersey
— Guernsey
— Isle of Man
— Cayman
— Bermuda
— Bahamas
— Barbados
— UAE
— Introduce economic substance
requirements from 1st January 2019.
— Permit access to company beneficial
ownership register for law enforcement
and tax authorities.
— Introduce MDR based on OECD work on
mandatory disclosure rules for the
Common Reporting Standard Avoidance
Arrangements and Opaque Offshore
Structures, by 31st December 2019.
— 92 countries assessed on three criteria:
1. tax transparency
2. good governance
3. real economic activity
— Countries assessed as non-cooperative
faced sanctions and blacklisting.
— Countries committed to making changes
to become cooperative avoided
blacklisting.
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OECD MDR on CRS Avoidance Arrangements and Opaque Offshore Structures— Model rules build on the principles in BEPS Action 12 and provide a framework for
national disclosure regimes
— Much more limited in scope than DAC6
— Similar to Hallmarks D(1) and D(2)
— Focus on schemes and arrangements to frustrate CRS reporting and on entities
and arrangements that have the effect of obscuring the beneficial ownership of
income and assets
— Intermediaries must disclosure details of arrangements meeting the set hallmarks
of “CRS Avoidance Arrangements” or “Opaque Offshore Structures”
— The disclosure needs to be made to the intermediary’s national tax authority
— The disclosure is required to be made within 30 days of implementation
— Similar definitions of intermediaries.
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Draft laws to be written and enacted by 31 December 201901
Lack of clarity around what is an “opaque structure”02
Possible closer alignment of definitions with DAC603
Automatic exchange with EU Member States (plus UK)04
Issues ahead
KPMG DAC 6 software solution
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A solution……. Classify, track and reportKPMG has developed DAC 6 software solution that will assist intermediaries and tax payers to determine whether their
organisation has any reporting obligations under this regime. The software will track the decision making process, allow local
DAC 6 hallmarks to be assessed and it will allow you to report arrangements to the tax authorities.
Why use a tool and not simply an excel spreadsheet?
There are a number of advantages to using a technology based solution
— We will provide a series of questions which will include bespoke or jurisdiction specific questions including
any domestic requirements, helping you determine whether an arrangement should be reported (or where
further information is required to determine this);
— A secure audit trail will show who did what and when and allow the decision making process to be
evidenced;
— Management will have a centralised view of the global status that indicates your organisations reporting
progress across all jurisdictions that you are active in. This is crucial for reporting arrangements within a 30
day timeline.
— Management information reporting and drill down analytics will help provide the ability to view or compare
different data sets to identify trends or risks associated with the reporting, including assessment by:
— arrangements reported,
— arrangements per tax, per jurisdiction, per hallmark.
How the solution works
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The configuration of the account allows the Manager to enter information about the intermediary organisation, entities
and business units as well as the members of the group. Details of the users are also entered and their roles (or ability
to access/view data) will also be configured, for example:
Configuration of the Account
User: Can initiate an arrangement
and input basics
Editors Stages 1 & 2: Responsible for data input for
stage 1 and stage 2 analysis
Reviewer: Has the ability to review the
arrangements. This ensures
a “4 eyes review process”.
Intermediary: Allows intermediaries to
answer arrangement surveys,
allowing continuity with
reporting.
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The solution encompasses ‘smart questionnaires’ which have been designed to take a user through a structured analysis
of the arrangement that needs to be reported. The questionnaire is dynamic and specific to the tax type and jurisdiction(s)
in question.
The structured process aims to:
— Determine based on the countries involved in the arrangement the questions that need to be
answered and which countries reporting is potentially required;
— Permits users to access ready made arrangements to help streamline your organization's
reporting obligations.
— Users can upload documents relating to the arrangement (e.g. where external advice that has
been received documenting whether an arrangement is reportable).
— The tool can be configured to mandate a secondary review of the conclusion reached for each
arrangement (or group of arrangements).
Arrangement analysis
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Arrangement analysis
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Arrangement Survey
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Predefined Arrangements
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Stage 1 Questionnaire
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Stage 2 Questionnaire
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Dashboard and landing pageThe management dashboard provides a centralized view of summary status highlighting any open actions across the
organization, business unit, user or jurisdiction (i.e. this will include arrangements not yet reported where they are
determined to be in-scope or those which are still unclassified).
The dashboard acts as a risk management tool and is configured to show how all arrangements are being progressed
within your organization, allowing action to be taken for those approaching deadline and not yet completed.
The dashboard shows the following:
— Jurisdictions where there are arrangements required to be reported.
— Progress bar indicator providing an overview of the in each jurisdiction.
— The dashboard visualizes the proximity to deadline and a breakdown of arrangements by their
progress in the reporting lifecycle.
— The dashboard contains a helpful internal messenger that allows you to contact other users within
your organization.
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Dashboard
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Chat function for easy exchange of information
Next steps
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Next steps
— Perform risk review if not already
— Educate internal stakeholders
— Discuss with businesses affected
— Ensure up to date with all country developments
— Determine best use of technology solutions
— Formulate approach with
customers/counterparties/advisors
Questions?
Thank you
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KPMG International have any such authority to obligate or bind any member firm.
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International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm
vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
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