On 14 July 2016, the Luxembourg Parliament adopted the bill n°6929 which introduces a new type of alternative investment fund in Luxembourg: the reserved alternative investment fund (RAIF – or fonds d’investissement alternative réservé, FIAR).
All you need to know about the Reserved Alternative Investment Fund (RAIF)
Luxembourg introduces draft law on country-by-country reporting
The modernization of the Luxembourg company law
Tax Alert - CJEU decision on VAT recovery of branch network support costs
UK votes to leave
Tax Insights: BEPS and business operations
Financial Services - connected?
2016 Worldwide Corporate Tax Guide
Do you know everything about international tax in Luxembourg?
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. We can help you navigate this shifting landscape. 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:
- Operating in a shifting tax landscape
Multinational companies continually adapt and transform their operating models as they seek to reach new markets and compete more effectively in mature markets. 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 execution capability and operational excellence.
Integration of tax planning and business operations
Whether companies seek to enter new markets or drive efficiencies in mature markets, leading companies understand both the optimal business configuration of their people and assets and the complexities of the international tax systems in which they operate. Operating models must be able to adapt to business drivers and the impacts of both direct and indirect taxes.
Compliance with applicable local and international tax laws and effective management of tax risks must also be carefully considered and integrated to drive the holistic effectiveness of the operating model. Operating model effectiveness is one of the cornerstones of successful competition and differentiation.
The EY Operating Model Effectiveness (OME) offering helps our clients to achieve their holistic, strategic objectives. Our advisory and tax professionals operate as one team to assist our clients with developing and implementing operating models driven by business needs and requirements while making sure that tax is an integrated part of the design of the operating model architecture.
- 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.
- Building effective supply chains
Today’s business environment for large, global companies is more fluid and complex than ever before. Companies are adapting their supply chains to respond to increasingly competitive market conditions and to deliver higher revenue and greater value to their shareholders and customers.
Now, more than ever, multinational companies are expanding their global footprint, to both seek new markets and to capture cost efficiencies. As part of this drive, they are increasingly expanding their supply chains.
With every development in the supply chain comes new costs and new risks to factor in
Alongside the advancement into new markets, leading companies are also further developing their existing supply chains to drive cost efficiencies and boost margins in their mature market operations.
Leading companies recognize the need for comprehensive, proactive planning
But whether it is to enter new markets or to drive efficiencies in existing markets, the new leading companies have one shared characteristic – they fully recognize that carrying out comprehensive, proactive planning across the new supply chain model can maximize the opportunities and mitigate the risks as much as possible.
Only with a truly holistic approach can all supply chain costs - including taxes - be assessed and managed.
The challenge of change
Every day companies face decisions about how to change their operations on a global basis.
The challenge in making such decisions is to look at the problem holistically, considering all facets of the problem. Tax consequences should be a part of the analysis because the tax impact of any business change may be very large and lead to a different result than an operations only analysis.
Often, companies will bring tax planning into the process only after the operational opportunities or alternatives have been narrowed and defined, limiting the effectiveness of the planning. Instead by integrating international tax planning at an earlier stage, different alternatives or operating models may emerge as the most effective overall.
With the integrated approach of our Tax Efficient Supply Chain (TESCM) practice, we can often unlock benefits that would not have been possible if such integration had not been present from the beginning.
- 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.
The OECD’s website indicates that the Base Erosion and Profit Shifting (BEPS) project “is looking at whether, and if so why, MNEs taxable profits are being allocated to locations different from those where the actual business activity takes place.” Based on the findings of an initial environmental scan, the OECD plans to implement what they describe as an “integrated and holistic approach to improve the concrete tools it has to address base erosion and profit shifting”. According to their website1 key areas of work of the OECD in which this is a current focus include:
- Harmful tax practices
- Aggressive tax panning
- Transfer pricing
- Tax treaties
- Tax policy and statistics
- Tax and development
- Tax Compliance
Visit our dedicated BEPS page for more informations and contacts
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