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S18 & EUSD S18 & EUSD

S18 & EUSD. Background to EUSD Cross border tax evasion in the EU Cross border tax evasion in the EU Threat of EU-wide WHT Threat of EU-wide WHT Exchange

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Page 1: S18 & EUSD. Background to EUSD Cross border tax evasion in the EU Cross border tax evasion in the EU Threat of EU-wide WHT Threat of EU-wide WHT Exchange

S18 & EUSD S18 & EUSD

Page 2: S18 & EUSD. Background to EUSD Cross border tax evasion in the EU Cross border tax evasion in the EU Threat of EU-wide WHT Threat of EU-wide WHT Exchange

Background to EUSDBackground to EUSD

Cross border tax evasion in the EUCross border tax evasion in the EU Threat of EU-wide WHTThreat of EU-wide WHT Exchange of informationExchange of information Some countries impose WHTSome countries impose WHT Knee-jerk reactionKnee-jerk reaction What consultation?What consultation?

Page 3: S18 & EUSD. Background to EUSD Cross border tax evasion in the EU Cross border tax evasion in the EU Threat of EU-wide WHT Threat of EU-wide WHT Exchange

Two sets of rules in one Two sets of rules in one reportreport

Rules are confusing – (especially if Rules are confusing – (especially if you deal with QI as well)you deal with QI as well)

Unit Trusts/CollectivesUnit Trusts/Collectives PEPs/ISAs/CTFsPEPs/ISAs/CTFs Joint accountsJoint accounts TrustsTrusts What harmonisation could be done?What harmonisation could be done?

Page 4: S18 & EUSD. Background to EUSD Cross border tax evasion in the EU Cross border tax evasion in the EU Threat of EU-wide WHT Threat of EU-wide WHT Exchange

DOCUMENTATION - DOCUMENTATION - EUSDEUSD

The language problemThe language problem Which number is the TIN?Which number is the TIN? Reluctance for sending originalsReluctance for sending originals Problems of certificationProblems of certification Why use the term TIN?Why use the term TIN? Client confusionClient confusion Confusion for people in non-EU Confusion for people in non-EU

countriescountries

Page 5: S18 & EUSD. Background to EUSD Cross border tax evasion in the EU Cross border tax evasion in the EU Threat of EU-wide WHT Threat of EU-wide WHT Exchange

What do the local tax What do the local tax authorities do with the authorities do with the

information?information? TIN TIN Place & date of birthPlace & date of birth Costs & BenefitsCosts & Benefits

Page 6: S18 & EUSD. Background to EUSD Cross border tax evasion in the EU Cross border tax evasion in the EU Threat of EU-wide WHT Threat of EU-wide WHT Exchange

Audit experienceAudit experience

S18 audit for 2004/5S18 audit for 2004/5 PenaltiesPenalties

Page 7: S18 & EUSD. Background to EUSD Cross border tax evasion in the EU Cross border tax evasion in the EU Threat of EU-wide WHT Threat of EU-wide WHT Exchange

Tax collected in 6 Tax collected in 6 MonthsMonths

Switzerland £69m Switzerland £69m Jersey £9mJersey £9m Guernsey £3mGuernsey £3m

Where has all the taxable income Where has all the taxable income gone?gone?

Page 8: S18 & EUSD. Background to EUSD Cross border tax evasion in the EU Cross border tax evasion in the EU Threat of EU-wide WHT Threat of EU-wide WHT Exchange

What now?What now?

““The Europeans love it and want to The Europeans love it and want to extend the EUSD to equities”extend the EUSD to equities”

The EU are reviewing the scope of The EU are reviewing the scope of the EUSDthe EUSD

Post implementation reviewPost implementation review Revenue simplificationRevenue simplification APCIMS initiativeAPCIMS initiative

Page 9: S18 & EUSD. Background to EUSD Cross border tax evasion in the EU Cross border tax evasion in the EU Threat of EU-wide WHT Threat of EU-wide WHT Exchange

IS ANYONE AWARE OF:IS ANYONE AWARE OF:

The mandatory requirement for The mandatory requirement for Authorised Investment Funds to pay Authorised Investment Funds to pay Distributions Gross to so-called No-Distributions Gross to so-called No-Net Liability Taxpayers?Net Liability Taxpayers?