• 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


    A weekly update on tax matters to 16 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 first seven deliverables under the OECD BEPS Action Plan were released yesterday, 16 September. These proposals represent a key step in the OECD's plans to ensure that profits are taxed where economic activities generating the profits are performed and where value is created.

    Yesterday's deliverables will be presented to the G20 Finance Ministers in Cairns on 20-21 September for political endorsement. There is likely to be political pressure to deliver some ‘quick wins’ although there remain a number of specific issues to resolve and there will be interaction with the 2015 deliverables, meaning that the recommendations will not be finalised until the 2015 deliverables are agreed.

    The proposals for country-by-country reporting (CBCR) stand out as a potential candidate for being implemented more quickly. Although there remain a number of implementation issues to resolve around filing and dissemination, there is likely to be pressure for the template to be adopted as soon as possible.

    The proposal documents are lengthy and we will be commenting more fully on the details and the implications for business in the next few weeks. We will hold a special Tax Focus web seminar on 18 September from 15:00 to 16:00. In that seminar we will look at the recommendations and what they mean for business. Register now to hear Claire Hooper and Simon Atherton discuss these developments, the next steps in implementing the deliverables and what will happen in 2015.

    We will be following that with a more in-depth Global webcast on 24 September (register here) and a breakfast seminar in London on 16 October (details available from your usual EY contact).

    In the meantime, we have summarised a few of the messages to come out of yesterday's deliverables:

    Action 1 (digital economy)

    Yesterday's report focuses mainly on the different potential options and acknowledges that it would be difficult, if not impossible to ring fence the digital economy from the rest of the economy for tax purposes. The OECD recognises that the business models and key features of the digital economy exacerbate BEPS risks and, therefore, must be addressed. It considers that other Actions will address these risks but at the same time a number of specific issues have been identified which must be taken into account through further work. That further work will be completed by December 2015 and a supplemental report issued at that time.

    Action 2 (hybrid mismatches)

    In its report the OECD provides both recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and for changes to the OECD Model Tax Convention to deal with transparent entities, including hybrid entities. The rules are similar to the previous draft proposals but do reflect representations made in some areas. There are still a number of areas where further work is required, which is to be completed by September 2015. There is also a reference to the possibility of transitional rules.

    Action 5 (harmful tax practices)

    The Forum on Harmful Tax Practices is to deliver three outputs: first, finalisation of the review of member country preferential regimes; second, a strategy to expand participation to non-OECD member countries; and, third, consideration of revisions or additions to the existing framework. The latest report outlines the progress made on the delivery of these outputs.

    As regards the review of the existing preferential regimes, the emphasis has been put on (i) elaborating a methodology to define a substantial activity requirement in the context of intangible regimes and (ii) improving transparency through compulsory spontaneous exchange on rulings related to preferential regimes. The OECD's primary focus is on a nexus approach, for example to allow benefits of a preferential intellectual property regime only to the extent that the related qualifying expenditure was incurred by that entity. Some countries, including the UK, have questioned the compatibility of the nexus approach with EU law.

    Action 6 (treaty abuse)

    The OECD report notes the agreement to a minimum level of protection against treaty shopping. At a minimum, countries should include in their treaties an express statement that their common intention is to eliminate double taxation without creating opportunities for treaty shopping and include:

    • The general treaty anti-abuse rule proposed, or

    • A Limitation on Benefits (LOB) rule supplemented by anti-conduit rules, or

    • Both an LOB and the general anti-abuse rule

    The Model provisions and commentary included in the report, particularly the LOB rule, are in draft form and further work will be needed on them. Further work is also required as to the implementation of the minimum standard.

    Action 8 (transfer pricing for intangibles)

    The report contains final revisions to Chapters I, II and VI of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2010) which clarify the definition of intangibles under the guidelines, provide guidance on identifying transactions involving intangibles, and provide supplemental guidance for determining arm's length conditions for transactions involving intangibles. Guidance on the allocation of returns derived from intangibles is in interim form because of the strong links to the 2015 transfer pricing work, relating to risks and capital and other high-risk transactions.

    Action 13 (transfer pricing documentation and CBCR)

    As expected the report contains a three tiered approach, being the master file, a local file and the CBCR template. The template requires multinational enterprises to report for each tax jurisdiction in which they do business the amount of revenue (split between related and unrelated parties), profit before income tax, income tax paid and accrued, total employment, capital, retained earnings and tangible assets, and to identify each entity within the group doing business in a particular tax jurisdiction and to provide an indication of the entity's main business activity.

    Multinationals are also required to provide tax administrations with high-level global information regarding their global business operations and transfer pricing policies in a master file that would be available to all relevant country tax administrations. This obligation does represent a significant change for many groups. The content of the reports are finalised, although there will be an assessment, no later than 2020, as to whether modifications or additional data may be required.

    Action 15 (multilateral instrument)

    The CFA has concluded that a multilateral legally binding instrument to implement BEPS measures is feasible and could be developed soon to at least incorporate tax treaty related BEPS measures. It recommends that a mandate be drafted for countries to further consider negotiating such an instrument.


    The independence referendum will take place tomorrow, 18 September. The national declaration is expected to be announced late morning or early afternoon on Friday 19 September.

    In the event of a No vote, Scotland will retain its current responsibilities with a gradual evolution of devolved powers. Each of the main political parties forming the pro-union campaign has outlined the powers it will potentially devolve to Scotland, with the proposals covering corporation tax, income tax and VAT. The three main Westminster parties have pledged to follow an ultra-fast timetable for powers to be devolved to Scotland if the country records a No vote. Work is due to start on 20 September with details of the proposals being published by the end of October and draft legislation being in place by the end of January 2015. Legislation would be unlikely to be passed until after the General Election in May 2015.

    In the event of a Yes vote, the Scottish Government will engage in discussions with the UK Government about the process and mechanisms for the transition to independence which the Scottish Government has set for 24 March 2016.

    Scotland is already set to take control of three taxes in 2015 and 2016 as a result of the Scotland Act. The Revenue Scotland Tax Powers Bill, which will allow the formal set up of Revenue Scotland to collect taxes, has now been passed and is awaiting Royal Assent. The first taxes to be collected by Revenue Scotland are: land and buildings transaction tax (which replaces stamp duty land tax) from 1 April 2015; landfill tax from 1 April 2015; and the Scottish rate of income tax which will be effective from 6 April 2016. In addition, the Act has granted new borrowing powers to the Scottish Government through capital borrowing and cash reserves.

    Whether Scotland votes Yes or No, there is no doubt that Scotland's tax landscape will change. The changes to taxes will be relevant not just for Scottish headquartered groups but all businesses with a presence or activities in Scotland. Your usual EY contact will be happy to discuss what those changes might mean for your business.

    We will be hosting an hour long webinar looking at the outcome and implications of the referendum on 23 September at 15:00, which will then be followed by a Tax Focus web seminar in October concentrating on the specific tax issues. To register for the 23 September webinar, please click here.

    The second report of our 2014 Global Tax Risk and Controversy Survey is now available. The report Managing Operational tax risk: Find the right people, processes and technology to manage record-to-report risks highlights where operational risk can come from, and describes some of the leading practices we see companies putting in place to manage risk more effectively.

    In the report, we examine what companies are doing with the resources they have now and investigate some of the issue companies may face as they move from current to future tax risk management models. We also identify eight key components of an optimal tax framework that can be adopted to mitigate operational tax risks and achieve control, value and efficiency across the entire record-to-report process.

    The report is available to download here.

    The use and enjoyment VAT rules affect any business providing services cross border, with a need to define where a supply is made and where that supply is actually consumed. We understand that HMRC is reviewing how UK businesses apply the rules and that there may be changes to the current rules, even where businesses have long standing agreements with HMRC.

    The concept of use and enjoyment most commonly arises in the telecoms, electronically supplied services and broadcasting industries. However, it is also a factor across many other service industries (eg banking and insurance and some parts of the oil and gas sector). Any change in the use and enjoyment rules would have a significant impact and service providers (and recipients) will need to consider the impact of any developments.

    Our tax alert sets out the current position, the possible changes in HMRC policy, the impact the potential changes could have on businesses and the issues that businesses might wish to consider.

    HMRC is looking again at its approach to tax governance, tax enquiries and risk assessment. Our first Tax Focus web seminar of the new season will address key topics in this area including HMRC's approach to corporation tax enquiries and VAT audits alongside its Know Your Customer campaign. We will also be looking at governance checks and senior accounting officer certification. The seminar will take place at 10:00 this morning, 17 September. You can register for the web seminar by clicking here at any time before the start.

    On 24 September, we will again be meeting with the team at HMRC responsible for the approach to senior accounting officer certification. These meetings provide an opportunity to share experiences and understand how HMRC is developing its response to the certification requirements. It will also be possible to raise any questions or concerns from business with HMRC's central team responsible for providing guidance generally to client relationship managers (CRMs). If you have particular issues or are able to provide feedback for us to share with HMRC, please get in touch with your local EY contact.

    Employment taxation: Recent developments

    Employee benefits and expenses consultations

    On 18 June, HMRC launched consultations on four aspects of employee benefits in kind and expenses with a view to reducing the administrative burdens on employers, individuals and HMRC. We have now responded to the consultations and our responses are available from your usual EY contact. As a reminder the consultations covered, an exemption for trivial benefits, the abolition of the £8,500 threshold for lower paid employment and form P9D, an exemption for paid or reimbursed expenses and the real time collection of tax on benefits through voluntary payrolling.

    Offshore employment intermediaries: Oil and gas industry

    HMRC has published guidance on a number of practical issues relating to national insurance contributions for offshore employment intermediaries where the workers are employed on the UK Continental Shelf (UKCS). The guidance covers the certificate process, the interaction between the UKCS and mariner rules, the interaction with the UK/Norway social security agreement, EU regulations and other bilateral agreements. The guidance also recognises practical difficulties in keeping track of employee movements for the purposes of Real Time Information, and states that HMRC would not seek to impose a penalty provided errors or delays are corrected by the following month.

    National Insurance Contributions Bill

    The National Insurance Contributions Bill 2014-15, which received its second reading on 8 September, includes measures accelerating the payment of disputed national insurance contributions in avoidance cases and a targeted anti-avoidance rule to prevent people from circumventing new legislation for employment intermediaries and offshore employers. The Bill has passed to a Public Bill Committee which is due to conclude by 28 October.

    Real Time Information: Late filing penalties

    In March 2014, HMRC announced its intention to stagger the introduction of late filing penalties under Real Time Information. HMRC has now published details of communications it intends to send to employers in advance of the new penalties coming into effect. The release explains that HMRC will apply filing penalties from 6 October 2014 for schemes with 50 or more employees and 6 March 2015 for all other schemes. Our tax alert provides a summary of the RTI penalties regulations.

    Government response to Public Accounts Committee (PAC) enquiry on tax reliefs

    HM Treasury has published the Government's response to the conclusions in a number of PAC reports, including the report on the PAC's inquiry into the administration of tax reliefs which was published in June 2014.

    In its response, HM Treasury defends the Government's approach to the administration and monitoring of tax reliefs. The Government rejects the PAC's suggestion that tax reliefs are “in effect, a form of public expenditure” and should be subject to the same parliamentary processes, stating that it would be unfeasible to try to manage tax reliefs separately as they are “integral features of a well-functioning tax system” which is managed by HMRC.

    Dual-resident EU-managed US company is able to rely on freedom of establishment principle

    In the case of Kronos Inc, the Court of Justice of the European Union (CJEU) has for the first time considered whether a taxpayer company, established under the Laws of Delaware but with its management in Germany, could rely on the EU freedom of establishment. The company held subsidiaries in the EU and in third countries. At the time, Germany operated an imputation system, which meant that a credit for underlying corporate income tax was only granted to a recipient of dividends where the dividends were taxable income of the recipient. Due to a participation exemption (with a minimum threshold of 10%) for foreign dividends, credit for the underlying corporate income tax was, therefore, denied. However, in the comparable German domestic situation the dividend would be taxable at the level of the shareholder and underlying tax would be credited and, where appropriate, refunded.

    The CJEU considered that the free movement of capital applied as the scope of the applicable tax rule covered both portfolio shareholdings and shareholdings enabling the shareholder to exert a definite influence on the company's decisions. In particular, the Court held that the 10% threshold did not mean that only controlling shareholdings were in the scope of the rule (so that the free movement of capital principle would have been inapplicable).

    However, the Court held that, in substance, no discrimination existed as Member States are free to opt for an imputation system or exemption method for avoiding economic double taxation in the field of dividend taxation and may apply these systems in parallel to domestic and foreign dividends.

    Our tax alert provides further details regarding the decision and its implications.

    European Commission consultation on cross-border mergers and divisions

    On 8 September, the European Commission published a consultation on the improvement of the existing framework for cross-border mergers and a possible framework for cross-border divisions of companies. The Commission is seeking in-depth information on the existing barriers in cross-border operations, what changes stakeholders believe are needed to the existing legal framework, and costs that could be saved through action at the EU level. Responses are sought by 1 December.

    CJEU judgment: VAT liability of books supplied on electronic media

    On 11 September, the CJEU handed down its judgment in the Finnish K Oy case. The CJEU held that EU law permits Member States to apply different VAT rates to printed books and books published on other physical means of support (eg CD, USB) provided they are not similar from the point of view of the average consumer in each Member State. Conversely, if a consumer considers that the purchase is of a book regardless of the medium on which it is supplied, the reduced rate of VAT should apply.

    How the UK implements the judgment remains to be seen. However, affected businesses may wish to consider the impact of the judgment now, particularly if a potential claim opportunity exists. The judgment does not consider the VAT liability of ebooks, an issue which will be considered in forthcoming infringement proceedings against France and Luxembourg.

    US proposals targeting perceived tax benefits related to ‘inversions’

    The prospect of more inversions among large, high profile US corporations (whereby they move their headquarters to a lower tax country by acquiring or creating a new holding company located outside the US) has attracted increased attention in Congress over the last few months.

    Last week, two US Democrat Senators released a bill that would address inversions by tightening the current restrictions on the deductibility of interest expense under section 163(j) (the earning stripping rules) for inverted groups. In addition, the proposal would require IRS pre-approval of foreign related-party transactions for 10 years. Our international tax alert provides further details.

    Spanish Government proposes amendments to the ETVE and participation exemption regimes

    In Midweek Tax News to 29 July 2014, we reported that the Spanish Government had published a draft bill which included proposed significant changes to the Spanish tax regime for foreign securities holding companies (the ETVE regime) and the participation exemption regime. The Spanish Government has now introduced a revised draft bill which includes amendments to the earlier proposals. If passed, the bill will apply from 1 January 2015. Our international tax alert provides further details regarding these proposals which are intended to introduce more flexibility to the ETVE regime and align it with the OECD BEPS project.

    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.

    Australia: The Government has recommended that the repeal of the Minerals Resource Rent Tax, which is levied on iron ore and coal mining profits, should apply from 1 October 2014.

    France/Luxembourg: On 5 September, the two countries signed an amendment to the double tax treaty between them which will give the right to tax capital gains on a disposal of shares in predominantly real estate entities to the State where the immovable property is situated.

    Mexico: A proposal has been made to extend the 4.9% interest withholding tax rate to 31 December 2015.

    Vietnam: Proposed tax relief measures to help Vietnamese enterprises cope with financial difficulties include corporate income tax incentives for certain business expansion projects and an expanded list of eligible industrial zones.

    India: The Delhi High Court has ruled 50% as a benchmark to evaluate “substantial value” on taxation of indirect transfers.

    Russia: The Russian Government has published a Model Agreement on Exchange of Information on Tax Matters which will be used as the basis for the conclusion of bilateral agreements with offshore jurisdictions. The Model Agreement is based on OECD standards (with certain amendments).

    Russia: An amendment has been proposed to legislation which would require Russian companies to disclose their beneficial owners to the Unified State Register.

    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: OECD update and EY webcast

    Email Claire Hooper

    + 44 20 7951 2486

    Scottish independence referendum

    Email Paul Gallagher

    + 44 131 777 2822

    2014 Global Tax Risk and Controversy Survey: Managing Operational Tax Risk report published

    Email Mandy Pachol

    + 44 20 7951 7092

    VAT: Possible changes to use and enjoyment rules

    Email Charles Brayne

    + 44 20 7951 6337

    Tax Focus web seminar 10:00 today: Tax governance, enquiries and risk management

    Email Sarah Chong

    + 44 20 7783 0859

    Senior accounting officer certification

    Email Paul Dennis

    + 44 121 535 2611

    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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  • 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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