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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 31 March 2015

    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 speak to the relevant contact listed at the end of this issue or to your usual EY contact.

    DPT comes into force today, Wednesday, 1 April with the first notifications by affected taxpayers due just six months after the first accounting period ending on or after today. The final legislation was published only last week and contains many changes from the draft clauses released in December 2014. On 30 March, HMRC published updated guidance (including a template for notifications) and we have also had a number of conversations directly with HMRC on how it intends to apply DPT in practice.

    DPT is an anti-avoidance measure aimed at perceived abuse involving insufficient economic substance within the supply chain or an avoided UK permanent establishment. The 25% rate of DPT is intended to be a penal rate to encourage affected groups to restructure. Furthermore, the rules provide an incentive for groups to be transparent about their international value chain, enabling HMRC to challenge transfer pricing more easily.

    Traditional single-sided transfer pricing methodologies are unlikely to be sufficient to satisfy HMRC in many cases. Instead, transfer pricing analysis based on the full supply chain is more likely to be demanded.

    Register now to hear Claire Hooper and Kate Alexander discuss how groups need to respond to DPT in order to meet their notification and tax obligations, to demonstrate whether their structures give rise to a charge and to take action to reduce the charge.

    On 26 March, the Court of Justice of the European Union (CJEU) released the opinion of the AG in the joined German cases of Beteiligungsgesellschaft Larentia + Minerva mbH & Co. KG and Marenave Schiffahrts AG. The cases concern the VAT recovery position of holding companies and whether entities that are not legal persons are eligible for VAT grouping.

    The AG opined that, where a holding company is actively involved in the management of a subsidiary, and it incurs costs in relation to capital transactions connected to that subsidiary, the VAT on this expenditure can be recovered in full and does not need to be apportioned between business and non-business activities. This is in line with the historic treatment in the UK but is at odds with the guidance issued by HMRC last year, which proposed restrictions on the basis of the business/non-business split and also requires a full recharge of costs.

    However, within the opinion, the AG also expresses a view that where the holding company and recipient are both members of a VAT group (which is common practice in the UK), this precludes any recovery of VAT on the basis of supplies of management services, because supplies within a VAT group are ignored for the purposes of VAT. The AG's opinion is not entirely clear on this issue but it is hoped that this will be resolved in the final judgment when it is issued by the CJEU.

    The AG also opined that all persons can be included in a VAT group and, accordingly, the German VAT grouping rules are too restrictive. If this approach is followed by the CJEU this may cast doubt on the UK's VAT grouping eligibility rules which, for instance, prevents limited partnerships from joining VAT groups.

    In September 2014, HMRC indicated in its updated VAT recovery policy on holding companies that it would review its policy again once the final CJEU judgment in these joined cases has been released. In light of the AG's opinion (and in the event that the CJEU follows the opinion), affected businesses may wish to consider the implications further.

    Please see our tax alert for further details.

    On 31 March, the OECD released its discussion draft in relation to Action 12 (mandatory disclosure rules) of the Base Erosion and Profit Shifting (BEPS) Action Plan. Action 12 notes the usefulness of disclosure initiatives in addressing the lack of comprehensive and relevant information available to tax authorities on tax planning strategies.

    This discussion draft provides an overview of mandatory disclosure regimes, based on the experiences of countries, including the UK, that have such regimes. It examines the key features of these regimes and uses these as a base for its recommendations for the design of a mandatory disclosure regime.

    In relation to its recommendations on the design of a disclosure regime for international tax schemes, the draft makes the following points:

    • Any arrangement that incorporates a ‘cross-border outcome’ should be treated as a reportable scheme.

    • Tax administrations should not apply a general threshold condition to cross-border schemes.

    • A taxpayer should only be required to disclose a cross-border scheme where the taxpayer or another group member was a party to the arrangement.

    • For domestic schemes, the disclosure obligation should extend to promoters and other intermediaries as well as to the taxpayer.

    • Where the person making a disclosure does not have enough information to provide full details, they should identify the persons who are believed to hold the missing information and certify that requests have been made to those persons.

    The draft invites comments to be submitted by 30 April 2015 and confirms that a public consultation meeting will be held in Paris at the OECD Conference Centre on 11 May 2015. Under the BEPS Action Plan, this work is expected to be completed by September 2015.

    Following the CJEU judgment in the case of PPG Holdings BV, HMRC previously announced that employers may deduct VAT paid on defined benefit pension fund management services, subject to the normal partial exemption rules, provided the employer is a party to the contract for those services and has paid for them. On 26 March, HMRC issued Revenue & Customs Brief 8/2015, outlining the specific circumstances in which HMRC will accept that tripartite contracts between the service provider, pension fund trustees and employer meet the condition that the employer must contract for the services.

    Specifically, HMRC states that where the tripartite contract demonstrates that the employer is the recipient of a supply of defined benefit pension fund management services and the employer has been issued with a valid VAT invoice for the full cost of the supply which it pays directly to the service provider, the employer may deduct the VAT incurred on those services in line with its residual recovery position. In this latter regard, HMRC does not accept that an equivalent increase in contributions to the pension fund (or any payment that is made by, or through, the pension fund) constitutes payment by the employer. If the employer recharges the net cost of those services to the pension scheme, HMRC considers that the recharge is consideration for an onward taxable supply and VAT is due accordingly.

    Affected businesses may wish to consider the implications of the updated guidance and, in particular, any retrospective claim opportunities if they have not already done so.

    The UK has agreed information sharing on tax with the US, EU and various other jurisdictions under which tax authorities will share details of bank accounts held by non-residents. The new International Tax Compliance Regulations require UK financial institutions to collect data on non-resident account holders who are subject to information sharing agreements and report this to HMRC.

    The UK will share this information under the EU's Directive of Administrative Cooperation, the OECD's Common Reporting Standard, and with the US in respect of FATCA through the UK's information exchange agreement with the US. The new regulations also replace the current UK rules on FATCA. The regulations come into effect on 1 January 2016 (except for the FATCA provisions which come into effect on 15 April 2016).

    HMRC has also issued a response to its consultation paper Implementing Agreements under the Global Standard on Automatic Exchange of Information to Improve International Tax Compliance. This is broadly in line with expectations and confirms the Government's commitment to tackling tax evasion and increasing international tax transparency.

    These developments reaffirm the UK's commitment to implementing the new rules by 1 January 2016. All financial institutions are expected to need to modify their current processes in order to comply.

    Our tax alert has further details.

    Royal Assent received for Finance Act 2015

    On Thursday, 26 March, Finance Act 2015 received Royal Assent, together with the Corporation Tax (Northern Ireland) Act 2015 (which devolves the rate of corporation tax to the Northern Ireland Assembly) and the Small Business, Enterprise and Employment Act 2015 (which includes various measures on corporate transparency).

    Upper Tribunal rules taxpayer can make rectification of partial surrender of insurance policies

    The Upper Tribunal has allowed the taxpayer's appeal in the case of Joost Lobler such that he can be taxed as if he rectified a mistake he made when surrendering life insurance policies. The taxpayer had asked for a partial surrender across all his policies to raise money to buy a house. This led to almost all the surrender proceeds being treated as taxable income even though the taxpayer had not made any significant real gain on the policies. If he had opted for a full surrender of some policies, much less tax would have been due.

    The First-tier Tribunal was sympathetic to the taxpayer but said it could not help. The Upper Tribunal overturned this decision, saying that the taxpayer was entitled to be taxed on the basis that he would have been able to rectify his mistake of asking for a partial rather than full surrender. However, other grounds in the original appeal, including human rights law, were rejected. In particular, the Upper Tribunal decided that the First-tier Tribunal was correct in refusing to consider questions of judicial review of abuse of power by HMRC.

    Details published of rules on tax-advantaged venture capital schemes

    A package of changes to the enterprise investment scheme (EIS) and venture capital trusts (VCT) was announced in Budget 2015. HMRC and HM Treasury have now published for consultation draft legislation and explanatory notes. The proposed changes include:

    • A rule that companies must receive their initial EIS/VCT investment within 12 years of making their first commercial sale

    • A new cap on total EIS/VCT investment that an individual company can receive of £20mn for ‘knowledge-intensive’ companies and £15mn for other companies

    • An increased limit to 499 employees for knowledge-intensive companies

    • Removal of the barriers between the seed enterprise investment scheme and EIS/VCT funding

    Although these changes have effect from 6 April 2015, some of them are subject to State Aid approval by the European Commission. As a result, the legislation was not included in Finance Act 2015. HM Treasury and HMRC have also urged investors to be cautious about investing more than allowed under the EU's general exemption from State Aid rules, which allows up to €15mn to be provided within seven years of the investee company's first commercial sale.

    Responses to the consultation are sought by 15 May 2015.

    HMRC succeeds in three avoidance cases at the Upper Tribunal

    HMRC has published details of three recent Upper Tribunal decisions as evidence of its success in challenging tax avoidance schemes. All three decisions confirmed the findings of the First-tier Tribunal.

    Two of the cases, Savva & Ors and Healey, were linked before the Upper Tribunal as there were considerable factual and legal similarities between the two cases. Each involved an arrangement where the taxpayers were sold a bond from which coupons had been stripped and which they could sell at a profit once the period for which the coupons were stripped had elapsed.

    The intention was that the profit realised by the taxpayers would be a profit of a capital nature and so would not be liable to income tax (whether as a discount, or otherwise). It would also be exempt from capital gains tax as a gain on the disposal of a qualifying corporate bond. However, the Upper Tribunal found that the profit made by the taxpayers was a discount and that the character of that discount was of an income nature. The Tribunal emphasised that it was the character of the discount in the hands of the taxpayers which had to be ascertained, not the character of the legal rights which the taxpayers bought and sold.

    The third case, Price & Ors, concerned an arrangement under which options over shares were acquired and exercised with the final sale of the shares acquired being at an apparent loss. The aim of the arrangements was that the capital loss arising could be translated into an income loss under the share loss relief provisions, so as to be available against other income. However, the participants in the arrangement did not make an economic loss on the transaction as each participant owed his subscription price for the shares to a discretionary trust of which he was the principal beneficiary. The principle economic effect of the scheme was to leave each taxpayer as the beneficiary of a trust to which he owed money. The judgment is not yet available but HMRC has indicated that the taxpayers' appeal has been rejected.

    Pension changes come into force on 6 April 2015

    In Budget 2014, the Government announced changes to the rules on taking benefits from defined contribution pension schemes. These tax changes are applicable from 6 April 2015 and affect the choices that individuals can make in connection with their retirement. Other changes affect those currently accumulating pension funds as well as those who have already retired and purchased annuities.

    Our tax alert summarises the changes.

    HMRC publishes consultation on restricting tax relief for bank compensation payments

    On 26 March, HMRC published a consultation document on the restriction of tax relief for compensation payments by banks. This follows an announcement in Budget 2015 that the Government would consult on these measures and that legislation would be included in a future Finance Bill.

    The consultation document contains various options and requests suggestions from the banking industry as to how the measure would work. It is expected that the measure, if enacted, would apply from the date the detailed rules were included in a Budget announcement.

    Representations are invited by 29 May 2015. HM Treasury and HMRC officials intend to hold a number of working groups toward the end on the consultation period.

    Upper Tribunal denies claim for tax relief for losses from a partnership

    HMRC has succeeded in its appeal in the case of Hamilton & Kinneil to the Upper Tribunal against a First-tier Tribunal decision that a UK corporate partner of a UK limited liability partnership (LLP) was entitled to relief for losses incurred by the LLP. Broadly, the rules in question limit the amount of loss relief that can be claimed by a corporate member of an LLP to the amount of capital that it has subscribed to the LLP, or the amount of the member's liability on a winding up, whichever is the greater.

    The Upper Tribunal decided that the legislation was intended to ensure that the losses that could be claimed from the LLP could not exceed the total capital contributed to it. In this case, the UK company claiming loss relief had become entitled to some of the LLP's capital but had not actually subscribed to any of it. Nor was the UK company required to make any actual contribution to the LLP on a winding up. Consequently, it was not entitled to relief in respect of any of the LLP's losses.

    The Upper Tribunal rejected the use of extra-statutory material as evidence since it did not find the legislation was “ambiguous or obscure”. In any case, it found that the material in question was of limited help to the taxpayer.

    Draft regulations released on the treatment of credit losses on a change of accounting method

    At the time of the Autumn Statement 2014, the Government announced a new rule to deal with transitional adjustments arising in respect of credit losses from lending activities on the adoption of IFRS 9. IFRS 9 is mandatory for affected companies for periods of account beginning on or after 1 January 2018, with early adoption permitted in certain circumstances.

    As a result of the new rule, all transitional adjustments relating to this accounting change will be spread over 10 years, thus preventing large one-off tax adjustments being necessary on the adoption of IFRS 9. The new rule will have effect for periods of account commencing on or after 1 January 2015.

    HMRC has published draft regulations and draft explanatory notes, requesting any comments by 22 May 2015.

    State Aid decision on UK aggregates levy exemptions

    The European Commission has announced that, following a State Aid investigation, it agrees that all but one of the UK's exemptions from aggregates levy are in line with State Aid rules. The Government intends to reinstate the relevant suspended exemptions with retrospective effect, although it will have to recover any unlawful aid provided by the one exemption (part of the shale aggregate exemption) that was held to be contrary to State Aid, subject to a de minimis threshold.

    Businesses affected by the decision may wish to review their position.

    Public Accounts Committee (PAC) reports on the effectiveness of tax reliefs and tax collection

    The PAC has issued new reports containing a number of comments on HMRC and making a series of recommendations. The report on the effective management of tax reliefs notes that there is limited data on the extent to which reliefs achieve their aims, in particular those intended to change behaviour. The PAC was also concerned that reliefs could be used to facilitate avoidance and recommended that HMRC monitors how much they actually cost.

    In its report on tax collection, the PAC also re-iterated a number of points it had made previously on avoidance, recommending a more aggressive approach to prosecuting tax evasion and dealing with avoidance by multi-national enterprises. It also urged HMRC to make a better case to HM Treasury for increased resources.

    UK signs tax treaties with Sweden and Bulgaria

    New tax treaties have been signed with Sweden and Bulgaria. They will each come into force once they have been ratified by the UK and respective foreign parliament, and diplomatic notes have been exchanged.

    Spain issues draft rules on country-by-country reporting (CBCR) and transfer pricing master files

    The Spanish Government has released a draft version of the new Spanish Corporate Income Tax Regulations which contain CBCR obligations and amendments to the rules on transfer pricing documentation. The regulations are expected to be adopted in the first half of 2015 and enter into force on 1 January 2016.

    The transfer pricing documentation requirements are very similar to the standards included in the report on BEPS Action 13 (transfer pricing documentation and CBCR) released by the OECD on 16 September 2014. This requires a master file and a local file. The master file must include detailed information on the organisational structure of the group; its business activities; intangibles; and information on any advance pricing agreements and other tax rulings the group may have obtained. The local file must include information relating to specific intercompany transactions.

    The proposed CBCR reporting obligations also echo BEPS Action 13. They apply to Spanish-headed groups and any other Spanish entities in groups headed in a jurisdiction without CBCR standards or an automatic exchange of information agreement with Spain.

    Our global tax alert has more details.

    Australia releases draft legislation on an investment manager exemption

    The Australian Federal Treasury has released draft legislation to implement the final element of the Australian investment manager regime (IMR) tax exemption for certain foreign funds and their foreign resident investors where the funds invest in certain Australian assets. The draft also proposes technical corrections to existing law.

    The object of the IMR is to encourage particular kinds of investment made into or through Australia by some foreign funds that have wide membership, or that use Australian fund managers. It will complete the project on the taxation of foreign funds, the first stages of which were enacted in September 2012.

    The draft law follows three previous draft versions and has been substantially re-written, including better alignment with the approach of the UK's equivalent investment manager exemption as noted in an Australian Government media release last December. The previous proposals have also been streamlined in various ways in this draft including improving the test for a widely-held fund.

    There is a short consultation period ending on 9 April, presumably for the law to be introduced in the May 2015 Budget sittings to implement the prospective measures from 1 July 2015.

    For further details, please see our global tax alert.

    Other global tax alerts

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

    India: New rules allow advance pricing agreements to be back dated by up to four years where certain conditions are met.

    Costa Rica: A wide-ranging draft law proposes to tax capital income and capital gains at 15%, as well as reforms to corporate income tax and withholding tax.

    China: In the aftermath of avoidance investigations, the State Administration of Taxation has issued transfer pricing rules on outbound related-party fee payments.

    Greece: A ministerial decree has tightened up the rules for cross-border transfer pricing deductions. Regulations implementing the rules are expected later.

    Other publications

    Please speak to your usual EY contact, or email us at, 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.

    Tax focus web seminar on diverted profits tax at 12:00 on Thursday, 2 April

    Email Claire Hooper

    + 44 20 7951 2486

    Advocate General opinion on VAT recovery position of holding companies

    Email Fiona Campbell 

    + 44 20 7951 3625

    OECD publishes discussion draft on mandatory disclosure of tax schemes

    Email Andrew Drysch

    + 44 20 7951 7076

    Updated guidance on the VAT recovery position of defined benefit pension schemes

    Email Mitchell Moss

    + 44 20 7951 2279

    Regulations enacted on automatic exchange of information

    Email David Wren

    + 44 20 7951 3235

    For other queries or comments please email

    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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