• Managing operational tax risk: survey highlights

    Finding the right people, processes and technology to manage record-to-report risks is no easy task. To consider how, see our survey’s leading practices.

  • Building a tax manifesto for manufacturing

    The global re-shoring trend is creating new opportunities for the UK, but our report shows it has limited time to set itself up for future high quality manufacturing.

  • Tax Insights (previously T Magazine): future of tax

    Whether it’s the media, politicians or corporations, everyone is becoming increasingly focused on tax. Don’t miss our eleventh edition, which examines the journey ahead.

  • 2014 tax risk and controversy survey highlights

    Bridging the divide between current and future risk management frameworks can be a challenge. Our survey reveals actions to help you prepare.

  • Managing indirect tax in the digital age

    Multinational companies are handling large quantities of complex data about indirect taxes. We outline hands-on approaches that can help deal with all that information.

  • Budget 2014

    Read our analysis of Budget 2014, including Budget Alert, which gives insight on employment, personal, corporate and indirect tax measures, plus EY ITEM Club comment.

  • OECD provides update on the BEPS Action Plan

    On January 23, 2014, the Organization for Economic Cooperation and Development hosted a webcast on the base erosion and profit shifting project. Learn more.

  • Tax Policy and Controversy Briefing goes online

    The speed of change continues globally. Keep up-to-date on tax policy, legislative and regulatory developments with our new web-based Tax Policy and Controversy Briefing.

  • Tax Transparency

    The trust an organisation builds with its stakeholders is critical, and tax transparency is a key dimension in building that trust. Find out how we can help.

Tax Services

We’ll help you navigate the global tax landscape

The business and tax landscapes have changed dramatically, and the pace and complexity of change continues to increase. Governments are tempering the need for revenue with increased competition for labor and capital. Tax authorities are adapting their enforcement strategies, focus and policies in response to the changing dynamics of business. Companies are balancing competing priorities, ensuring they maintain compliance while adding value.

We can assist you with these critical issues in today's tax environment, including:


Building a tax manifesto for manufacturing 658K, August 2014



  • Midweek Tax News

    Archives...

    A weekly update on tax matters to 9 September 2014

    Midweek Tax News provides you with a succinct overview of the key tax developments that have occurred each week, to allow you to stay up-to-date on tax issues that may have an impact on your business. If you would like to discuss an article in more detail, please do speak to the relevant contact listed at the end of this issue or to your usual EY contact.

    The OECD has confirmed the launch of the first seven deliverables under the BEPS Action Plan will take place on 16 September 2014. The BEPS Action Plan provides for 15 Actions to be delivered by 2015. We understand that a holistic review process will be built into 2015's work to take into account the relationships and interactions between all of the BEPS Actions and proposals and we also understand that decisions on implementation mechanisms for the seven deliverables provided next week, will be taken in 2015.

    This set of agreed measures on the seven Actions will be presented to the G20 Finance Ministers in Cairns on 20-21 September 2014 for political endorsement. As part of the official launch, on 16 September 2014 there will be a press conference hosted by Angel Gurria (OECD Secretary General) and Pascal Saint-Amans (director of the Centre of Tax Policy and Administration) at 1:00 pm (BST) and an OECD hosted webcast at 3:00 pm (BST). This is expected to discuss the details of the first set of deliverables, the involvement of developing countries and the input from stakeholders, as well as the planned next steps.

    The Actions on which deliverables will be issued are:

    Action 1 (the tax challenges of the digital economy): We expect the report will focus on the options available and the interaction with other BEPS Actions, rather than specific actions.

    Action 2 (hybrid mismatch arrangements): We are expecting a focused report along the lines of that previously proposed with further work to be done on a number of issues, including implementation.

    Action 5 (harmful tax practices): We expect that this will include consideration of Patent Box regimes and potential options for demonstrating substance.

    Action 6 (tax treaty abuse): We expect proposals for changes to the Model Treaty and Commentary, probably with a ‘menu’ approach for countries to choose from, creating a ‘minimum’ treaty standard to counter tax avoidance.

    Action 8 (transfer pricing for intangibles): There is a strong interaction between this work and the 2015 work on the Actions related to risk, capital and the associated special measures and we expect this to be reflected in next week's deliverable.

    Action 13 (transfer pricing documentation and country-by-country reporting): We expect revised transfer pricing guidelines and a final version of the country-by-country reporting template. Guidance as to how the template will operate and how it will be shared between countries is not expected until January 2015.

    Action 15 (developing a multilateral instrument on BEPS): We are expecting some form of feasability review of the available options.

    Now is the time to be considering the impact of these developments on your business if you have not already done so. Please speak to your usual EY contact, who will keep you updated with developments and their implications.

    2014 Global Tax Risk and Controversy Survey report and webcast

    Increased reputational, legislative and enforcement risk are putting additional pressure on tax resources, processes and technology for businesses large and small. Every company has to deal with operational tax risk but few do so with absolute certainty or complete confidence.

    In the second report of our 2014 Global Tax Risk and Controversy Survey, which launches on 11 September, we highlight sources of operational risk and describe leading practices companies may want to institute to help achieve regulatory compliance while driving business performance. At 3:00 pm (BST) on Thursday, 11 September, please join our panel of professionals as we discuss key findings and drivers of increased operational risk. In our report we find that:

    • Sixty-eight percent of survey respondents say there are insufficient resources to cover tax function activities.

    • Sixty-two percent of the largest companies surveyed have either created or refreshed their tax risk policy in the last two years.

    • Only twenty-five percent of companies say their internal controls are documented in all jurisdictions, regardless of whether or not it is required by regulators.

    • Only nineteen percent of respondents use dedicated software tools to enable and support notice information, data request and tax audit management. The remainder use email, spreadsheets or no technology at all.

    To register for the webcast please click here.

    Tax Focus web seminar 10:00 am 17 September: Tax governance, enquiries and risk management

    As these developments play out at a global level, HMRC is also looking again at its approach to tax governance, tax enquiries and risk assessment. As a reminder, our first Tax Focus web seminar of the new season (which will take place at 10:00 am rather than 1:00 pm as previously) will address key topics in this area including:

    • Governance checks: How does HMRC evaluate tax governance and what evidence is needed to support a ‘low risk’ rating?

    • Senior Accounting Officer (SAO) certification: Can businesses that fall within the SAO regime now expect to see more scrutiny of the work undertaken to support the SAO certificate?

    • HMRC's approach to corporation tax enquiries and risk assessment: How is HMRC approaching corporate tax enquiries and how can they be effectively managed?

    • VAT: How is HMRC approaching VAT audits and where are the key areas of focus?

    • AYE/NIC: How has the Know Your Customer campaign, which focuses on the full employment tax compliance process, affected businesses and how can they best prepare?

    • HMRC settlement initiatives: How can organisations benefit?

    • Follower notices and accelerated payments: How has the recent legislation in this area impacted businesses with open issues?

    Register now for our next Tax Focus web seminar at 10:00 am (BST) Wednesday, 17 September 2014 to hear Claire Hooper, Jim Wilson, Andrew Hinsley and Charles Brayne discuss the latest developments on these matters.

    The Upper Tribunal (UT) has upheld the decision of the First-tier Tribunal (FTT) in the case of The Partners of the Vaccine Research Ltd Partnership & Anor which concerned the availability of loss relief to members of a partnership in respect of expenditure relating to research and development which was intended to qualify for capital allowances.

    The arrangement involved individual partners contributing funds of £193mn (a substantial part of which were borrowed from a bank) to the partnership. Of those funds only £14mn was ultimately paid to a vaccine research company which actually carried on research and development. The arrangements were structured such that the partners would receive sufficient income to ensure that their loans would be repaid.

    The UT found that the partners were only entitled to sideways loss relief for that part of the expenditure relating to research and development which was ultimately spent on that development (the £14mn) and in relation to interest payable on their loans to the extent that these were used to produce trading income (ie, to the extent of the £14mn).

    Perhaps the most interesting aspect of this case is that, rather than following the approach in HMRC v Tower MCashback and identifying which part of that expenditure was ‘real’, the FTT chose to split the partnership's activities between trading and non-trading and grant relief only in respect of the latter. The UT was content to follow this approach.

    Whilst the UT agreed with the FTT's conclusion that the location of the Jersey partnership's trade (relevant to whether sideways loss relief was available) was the UK, it did not agree with the FTT's reasoning that the ‘transparency’ of partnerships and location of the individual partners were relevant. The FTT should have focused on where the relevant activity of the partnership was located (ie, in this case, also the UK).

    In the case of Philpott & Anor v HMRC the First-tier Tribunal held that the value of an in specie contribution made by an employer to a funded unapproved retirement benefits scheme (FURBS) was taxable on the relevant individuals, despite a claim by them that the contribution was not ‘for or in respect of’ any of them and so could not be taxable under section 386 ITEPA 2003.

    The claim related to real estate contributed to the FURBS and then from the FURBS into a limited liability partnership (LLP) set up by the FURBS (among others). Three of the individuals received lump sums shortly thereafter, which were likely to have been funded by additional borrowing in the LLP. The Tribunal considered that, although it was possible in principle for ‘general funding’ contributions to be made to a FURBS, in this case the lump sums in question could not have been determined other than by reference to the in specie contributions. The implication, therefore, was that the in specie contribution was in fact a contribution on their behalf.

    The FII GLO litigation has returned to the High Court following the various referrals to the Court of Justice of the European Union. As part of the arguments before the High Court, HMRC sought to amend certain aspects of its defence to the claims brought. In particular, it wished to amend its argument on the application of the ‘standstill’ provision to third country foreign income dividends (FIDs). The standstill provision allows certain legislation, in force as at 31 December 1993, to continue, even though it would otherwise infringe the treaty.

    The Court of Appeal has now upheld a decision of the High Court, refusing HMRC permission to amend its defence. The Court of Appeal held that the issue had already been decided in earlier court hearings. Furthermore, any attempt by HMRC to argue that the obligation imposed on a UK company under the FID regime to account for advance corporation tax on dividends paid by it out of dividends received from third countries was a separate restriction, protected by the standstill provisions, from that denying a tax credit to the shareholder receiving the FID, would amount to an abuse of process.

    The point was one which could have been taken in previous hearings, but was not. Indeed, the arguments previously run by HMRC were based on the premise that there was one composite FID scheme.

    HMRC is not appealing against the Upper Tribunal decision in BUPA Insurance Limited which addressed the meaning of beneficial entitlement in the context of the consortium relief legislation. The decision is now final.

    The Upper Tribunal held that contractual obligations to pay earn-out consideration on the acquisition of shares in a target company equal (or nearly equal) to the distributions made on those shares did not deprive it of beneficial entitlement to any distribution made by that company.

    The Tribunal also noted that in the Indofoods case the notion of beneficial ownership took an international fiscal meaning which connoted “full privilege to directly benefit” from the interest in question (arising from a chain of lending). The Tribunal found that such a notion was a very different test of beneficial ownership to ownership rights which amount to more than a mere legal shell. Accordingly, the Tribunal found that the UK domestic legal authorities that have construed “beneficial ownership” were undisturbed by Indofoods.

    Further detail on the case can be found in Midweek Tax News to 8 July 2014 (click here).

    In the case of Bookit Ltd, the First-tier Tribunal considered whether credit and debit card handling fees charged to customers making bookings for cinema tickets were exempt from VAT under EU law.

    In 2006, the same taxpayer successfully argued in the Court of Appeal that its card handling fees then being charged were exempt from VAT. In other cases involving very similar issues, the Tribunal has followed the Court of Appeal's decision. However, in the present case, HMRC maintained that subsequent case law of the Court of Justice of the European Union (CJEU) gave rise to a real doubt as to the correctness of the Court of Appeal's decision. As the Tribunal had reservations as to the scope of the exemption under EU law for ‘transactions concerning payments’, it decided that a reference should be made to the CJEU on this issue.

    Notwithstanding this, the Tribunal was satisfied that the exclusion from exemption for debt collection did not apply in the present case. The Tribunal also held that the arrangements involving the taxpayer's supplies were not ‘abusive’ for VAT purposes. The Tribunal declined HMRC's invitation to make a reference to the CJEU on these latter two issues.

    Any taxpayers providing similar card handling services might expect HMRC to take action to protect its position in the event the CJEU finds that such services do not fall within the exemption.

    On 3 September, the CJEU handed down its judgment in the case of GMAC UK plc, a UK referral from the Upper Tribunal. This case concerns whether a taxpayer, who makes two sales of the same goods, is entitled both to rely on the direct effect of a provision of EU law in relation to one transaction and to rely on the provisions of domestic VAT law in relation to the other transaction, where this would lead to an overall VAT result which neither EU law nor domestic law intended. In the circumstances of the present case, the CJEU answered this in the affirmative. Our tax alert provides more detail on the judgment and its implications.

    This judgment and the ongoing domestic litigation involving both GMAC UK plc and British Telecommunications plc will be of interest to any businesses which have submitted retrospective (pre-1997) claims for VAT bad debt relief.

    Employment taxation: Recent developments

    Short term business visitors: Further HMRC updates

    In Midweek Tax News to 2 September, we reported that HMRC was expected to shortly issue a revised ‘Appendix 4 agreement’ with regard to the PAYE arrangements for short-term business visitors. We can now confirm this has been published on HMRC's website. Our tax alert considers the impact of the changes to the agreement in detail.

    Consultation on the reform of travel and subsistence tax rules

    As part of the Government's consultation on the reform of the travel and subsistence tax rules, it is holding a series of meetings to canvas opinions on the general framework of any future consultation. In this regard, we attended a meeting on 2 September with HM Treasury. Please liaise with your usual EY contact to discuss the themes arising from this meeting.

    Employee benefits and expenses consultations

    On 19 August, we held an event for employers to discuss the HMRC consultations on employee benefits and expenses, and HM Treasury's call for evidence on remuneration practices. A representative from the Treasury was also present and involved in the discussions. Our tax alert contains an overview of the key themes.

    2014 Employment Tax training workshops

    Our popular Employment Tax training workshops are running this year in October and November. These are aimed at individuals working in HR, finance, tax and payroll, who encounter employment tax issues. These half day sessions will cover areas such as policy, compliance and pay and benefits pitfalls. Please click here to register for a workshop at a location convenient for you.

    Employment intermediaries: New reporting requirements

    The Finance Act 2014 introduced measures relating to onshore and offshore employment intermediaries designed to prevent the avoidance of income tax and national insurance contributions in situations where intermediaries are used to disguise employees as self-employed.

    From 6 April 2014, intermediaries must treat workers as employees when all the qualifying conditions within the recently revised agency legislation are met, and where that worker, provides services in the specified circumstances.

    From 6 July 2015, intermediaries will have to report to HMRC details of all workers and their payments where PAYE is not operated. On 4 September 2014, HMRC published guidance as to these reporting requirements. The guidance confirms, inter alia, the following:

    • Each tax year will be divided into four reporting periods, and reports are required to be completed within one month of the period end. The first report must be received by HMRC by 5 August 2015 and will cover the three month period from 6 April 2015 to 5 July 2015.

    • Each report must include information on the intermediary and the workers in question, details of hours worked and amounts paid, and also details of any payments to other parties for the workers' services.

    • Penalties will arise in relation to reports that are late, incomplete or incorrect, and HMRC intends to publish more information on these penalties in due course.

    Pension Schemes Bill: Second reading 2 September 2014

    The Pension Schemes Bill will implement a range of changes to existing pension legislation as part of its aim to provide wider choice. It will introduce defined ambition pensions which are intended to encourage greater risk sharing between parties and allow savers to have greater certainty about their retirement savings. Together with the provisions in the draft Taxation of Pensions Bill, on which consultation has now closed, the Pension Schemes Bill provides people with greater flexibility over how to access their defined contribution pension savings.

    The Pension Schemes Bill has now passed its second reading and will now move to consideration by a Public Bill Committee. The Committee stage is due to conclude by 6 November 2014. Further Government amendments, including those addressing the ‘guidance guarantee’ will be introduced at a later stage.

    UK/USSR double tax convention: Tajikistan

    On 1 July 2014, a new double tax convention between the UK and Tajikistan was signed and will enter into force when both countries have completed their parliamentary procedures and exchanged diplomatic notes.

    Meanwhile, HMRC has published Statement of Practice 14/2014 which supersedes Statement of Practice 4/2001. The earlier Statement made public the UK's understanding, at that time, of the status, in relation to those former Soviet Republics that had been recognised by the UK as independent sovereign states, of the UK/USSR double taxation convention. It confirmed that the UK/USSR convention continued in force for Belarus, Tajikistan and Turkmenistan.

    The UK Government has been informed that Tajikistan considers that the UK/USSR convention never had effect in Tajikistan as Tajikistan did not complete the procedures necessary in order for the convention to have effect under its domestic law.

    The new Statement of Practice states that the UK will not apply the terms of the UK/USSR convention in the case of residents of Tajikistan: for profits arising on or after 1 April 2014, in the case of corporation tax; and for income and gains arising on or after 6 April 2014, in the case of income tax and capital gains tax. The UK will continue to apply the terms of the UK/USSR convention in the case of residents of Tajikistan in respect of profits, income and gains arising before these dates. In these circumstances, section 25 TIOPA 2010 will not prevent a claim to unilateral relief in respect of Tajik taxes levied on profits, income or gains arising in Tajikistan.

    China begins anti-avoidance investigations into service fees and royalty payments

    The General Office of China's State Administration of Taxation (SAT) has issued an internal notification requiring tax bureaus at a local provincial level in China to investigate arrangements involving the payment of significant service fees and royalty payments to overseas related parties (in particular those in low tax jurisdictions) in the period from 2004 to 2013. The SAT has asked the tax bureaus to assess the reasonableness of such payments from both a business purpose and commercial substance perspective. Following their assessment of such payments, the tax bureaus are to submit their reports to the SAT by 15 September 2014. An investigation procedure will commence should the report suggest there may have been tax avoidance in any particular case.

    Our tax alert provides further details.

    VAT treatment of intra-EU B2B supplies of goods: EY/European Commission study

    This study is relevant for all companies engaged in the business to business (B2B) cross border supplies of goods in the EU. In order to address the inherent problems of the current B2B intra-EU supplies of goods taxation model, the European Commission has identified five alternative taxation models. As mentioned previously in Midweek Tax News, the European Commission has appointed EY to undertake a study of the VAT and cost implications of those models. The guiding principle of this study is to align the simplicity, cost, and safety of engaging in business activities across EU Member States with doing business domestically.

    An essential element of this study is an online survey for businesses across all 28 Member States to complete and provide comments on the current taxation model and the alternative five options. In particular, the European Commission would like to encourage small and medium enterprises (SMEs) to participate in this survey, as it understands that, as a result of the current EU legislation, SMEs have historically been less likely to engage in the B2B cross-border supply of goods.

    The survey is open until 12 September 2014, so please take this final opportunity to let us know your views on how new legislation in this area could affect how you do business across the EU and how this is reported in the future.

    Please click here to complete the survey.

    Canada releases draft legislative proposals following 2014 federal budget

    Canada's Department of Finance has released for public comment a package of draft legislative proposals and explanatory notes relating to a number of measures announced in the 2014 federal budget, as well as a number of technical changes to the Income Tax Act and the Income Tax Regulations.

    A key development is that the Canadian Government has decided to defer the introduction of any anti-treaty shopping measures, and will instead await further work by the OECD and G20 on their base erosion and profit shifting initiative (for which see the first item in this week's edition of Midweek Tax News).

    Our international tax alert has an overview of the changes. Separate alerts are also available covering the international tax measures and the financial services implications of these legislative proposals.

    Other international tax alerts

    Please see links to a selection of our international tax alerts in respect of the following developments. Additional articles are available in our Global tax alert library.

    India: The Ministry of Finance released its annual report which provides key statistics for the 2013-14 financial year and highlights the continued focus of the Indian tax authorities on transfer pricing and the taxation of cross-border transactions.

    Singapore: The Inland Revenue Authority has released a consultation paper on proposed revised guidance on transfer pricing documentation which includes a requirement to prepare and keep contemporaneous transfer pricing records.

    Australia: The Government has now passed a Bill repealing the Minerals Resource Rent Tax, which is levied on iron ore and coal mining profits, although the precise date of repeal is yet to be determined.

    Other publications

    Please speak to your usual EY contact, or email us at eytaxnews@uk.ey.com, if you would like to receive a copy of our regular indirect tax newsletter, or information about our other publications.

    Further information

    If you would like to discuss any of the articles in this week's edition of Midweek Tax News, please contact the individuals listed below, Claire Hooper (+ 44 20 7951 2486), or your usual EY contact.

    Base erosion and profit shifting: Forthcoming documents and activity

    Email Claire Hooper

    + 44 20 7951 2486

    Upcoming webcasts

    2014 Tax Risk and Controversy Survey report and webcast

    Email Mandy Pachol

    + 44 20 7951 7092

    Tax Focus web seminar 10:00 am 17 September: Tax governance, enquiries and risk management

    Email Sarah Chong

    + 44 20 7783 0859

    Upper Tribunal considers the commercial reality of expenditure

    Email Tom Passingham

    + 44 20 7951 2846

    First-tier Tribunal rules on taxability of in specie contributions to a FURBS

    Email Andrew Drysch

    + 44 20 7951 7076

    FII GLO: Application of CJEU referrals

    Email Mike Gibson

    + 44 20 7951 0568

    Meaning of beneficial ownership

    Email Mike Gibson

    + 44 20 7951 0568

    VAT liability of credit and debit card handling fees

    Email Andrew Bailey

    + 44 20 7951 8565

    Reliance on both domestic VAT law and direct effect of EU law

    Email Jamie Ratcliffe

    + 44 12 1535 2255

    For other queries or comments please email eytaxnews@uk.ey.com.

    Back to the top

  • Operating in a shifting tax landscape

    The global tax landscape continues to change in a dramatic fashion, with near-constant news hitting the headlines regarding shifting tax policy, increasing levels of enforcement and the growing potential of reputational risk.

    Competing priorities

    Multinational companies now have to balance more competing priorities than ever before, ensuring they protect their business by monitoring and responding to changes in policy, legislation and tax enforcement, while at the same time ensuring they not only maintain the highest levels of compliance but also add value from the tax function.

    Governments work to secure each tax dollar they're due

    From a policy perspective, all governments want their country to be viewed as an attractive place to do business, to attract jobs and capital in an increasingly competitive globalized arena.

    At the same time, they want to increase the amount of revenue they bring in. Governments are treading a fine line, constantly assessing how to secure the tax revenues they see as rightly theirs, while at the same time being in direct competition with other nations, making sure they do not scare off mobile capital.

    Tax administrations for their part are adapting their enforcement strategies, focus and policies in response to the changing dynamics of business. They are working to ensure that their resources are being applied to the right issues and taxpayers. They share more leading practices and taxpayer information with their foreign counterparts, to help them collect every dollar due.

    Disputes are on the rise

    The result has been more  frequent, complex and higher value disputes between taxpayers and taxing authorities — a trend that is only increasing as countries collaborate together and as emerging markets gain in stature and influence, taking a more sophisticated approach to taxation. Penalties are becoming more stringent and the threat of reputational risk has risen significantly in recent months.

    We can help you to navigate a route through this complex landscape.

    We can help you monitor and react to quickly-changing tax policy and assess the economic and fiscal impact.

    Where tax policies might create an impediment to your business that is unintended by policy makers, we can help you to collaborate – either solely, or as part of a broader grouping of companies who share a common objective – with government to:

    • Explain the impediment
    • Develop alternative policy choices which are logical and well thought out
    • Model the potential outcomes
    • Deliver an alternative choice to the government in a form with which policy makers can comfortably work

    We also help you address your global tax controversy, enforcement and disclosure needs.

    We focus on pre-filing controversy management to help you properly and consistently file your returns and prepare the relevant back-up documentation.

    Where a controversy has already occurred, our professionals leverage the network's collective knowledge of how tax authorities operate, and increasingly work together, to help resolve difficult or sensitive tax disputes. To ensure that continuous performance improvements are instigated after a controversy, we work with EY's other tax professionals to ensure that similar events are less likely to occur.

    Below you can access our views and analysis of some of the substantial policy and enforcement trends and issues at play today.

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    Alternative Dispute Resolution: a new chapter emerges

    As tax authorities adapt their enforcement in response to changing business dynamics, so must taxpayers. One key is the knowledge of alternative dispute resolution tools.

  • Seizing the opportunity in Global Compliance and Reporting

    Global Compliance and Reporting (GCR) is at a tipping point, with risks on the rise. Many companies distribute responsibility for GCR processes throughout their organization, creating a patchwork. Local jurisdictions are rewriting regulations, focusing more intently on the collection of tax revenues and sharing more taxpayer information across borders.

    Due to the combination of evolving business models, transforming finance functions and an increasingly complex regulatory landscape, there are new opportunities to better optimize efficiency, control and value, to help mitigate risk and improve performance.

    What is Global Compliance and Reporting?

    GCR comprises the key elements of a company's finance and tax processes that prepare statutory financial and tax filings as required in countries around the world. These duties include:

    • Statutory accounting and reporting
    • Tax accounting and provisions
    • Income tax compliance
    • Indirect tax compliance
    • Governance and control of the above processes

    GCR activities reside in the middle of a broader set of record-to-report (R2R) processes. R2R is the intersection between any company's finance and tax departments and is used to capture, process and store information that is essential to statutory accounting, tax compliance and reporting. Any change to R2R processes, information, finance systems, roles and responsibilities will have a direct impact on GCR processes.

    Helping you meet the new GCR demands

    Fast changing compliance and reporting requirements are more demanding on tax and finance functions today than ever before. So how do you improve control and quality, manage risk, create efficiency and drive value?

    Our market-leading approach combines standard and efficient processes, highly effective tools and an extensive network of local tax and accounting subject matter professionals.

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  • Building effective supply chains

    As multinational companies seek to reach new markets and compete more effectively in mature markets, they are adapting and differentiating their supply chains. Companies’ operating models need to cater for efficiency and scale in mature markets, while having the flexibility and local ability to support growth in emerging markets. Consequently, driving true shareholder value requires an operating model that combines global and regionally differentiated processes, and integrates these with local striking power and operational excellence.

    Leading companies recognize the need for integrating tax in their business planning and decision processes

    Whether companies seek to enter new markets or drive efficiencies in mature markets, leading companies understand the complexities of the international tax systems. The impact of both direct taxes and indirect taxes needs to be carefully considered and integrated to drive the effectiveness of the operating model while complying with all applicable local and international tax laws and effectively manage all tax risks. Operating model effectiveness is becoming one of the cornerstones of successful competition and differentiation.

    Our approach

    The EY TESCM offering helps ensure you do just that. Our advisory and tax professionals operate as one team to assist our clients with developing and implementing operating model optimization where business needs and requirements are the driver while making sure that tax is an integrated part of the design of the operating model architecture.

  • Managing mobile workforce risk

    In today's globally integrated, tightly regulated and increasingly competitive business environment, one critical success factor stands out: people. It’s no wonder that leading companies are focusing their efforts on:

    • Attracting and retaining the right people
    • Global talent deployment and mobility
    • HR and payroll effectiveness
    • Risk, governance and compliance

    Managing the risks of mobile employees

    While optimizing the competitive advantage of your people has long been a core objective, a more recent set of trends in the tax landscape means that large companies with an internationally mobile workforce are at a higher risk of tax noncompliance and resulting controversy than ever before.

    Fortunately, an increasing number of organizations are currently either planning or embracing a wider process of change for their mobility teams.

    Unintended tax compliance obligations

    These travelers are increasingly creating unintended tax compliance obligations, and the resulting risks are not just personal. They are felt at the corporate level, with the corporate tax function often unaware of the extent of the spreading problem. Tax administrations are becoming increasingly aware of the issue, however, and are very effectively using new technology to identify where a tax obligation has arisen. In a rising tax enforcement landscape, this issue has significant potential to grow.

    Managing these risks should be a burning platform issue for multinational companies.

    Will your tax risks prompt a tax audit?

    What may start as a relatively simple personal income tax compliance issue can quickly create a ripple effect, with risks such as the creation of a permanent establishment, an employment tax audit or the payment of a significant related penalty all occurring at the corporate level.

    Companies, recognizing the spectrum of reputational, personal and financial risks related to tax, are making strong efforts to be compliant. There is an increasing acceptance that such issues are becoming increasingly urgent from both a reputational and a financial perspective.

    How we are helping companies

    Our Human Capital network embeds processes and technology that will help companies to identify and manage short-term business traveler-related risks before they occur. Where controversy has already arisen, our global Tax Controversy network can use our insights into the culture and processes and relationships with each key tax administration to remediate issues. With prior year issues being rapidly unearthed, and with tax administrations focusing on this issue more than ever before, the time to act is now.

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EY - London skyline and River Thames

Supporting fast growth businesses and entrepreneurship in London

London is a global business hub. Find out how we bring our experience of the city and its issues together with specific industry knowledge to support London businesses.


EY - Building a tax manifesto for manufacturing

Building a tax manifesto for manufacturing

The global re-shoring trend is creating new opportunities for the UK, but our report shows it has limited time to set itself up for future high quality manufacturing (658K, August 2014).