Global Financial Services and Insurance Indirect Tax Conference
A world of change
1 - 3 December 2020
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Conference agenda
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Governments around the world are looking to reform indirect tax legislation to deal with the effects of COVID-19 and the rise of digital services. This session will cover specific initiatives to reform VAT and GST for financial services businesses including the scope of the exemption, VAT recovery methodologies and VAT grouping.
Investment Management
A digest of recent developments throughout Europe, from the perspective of managers and funds:
- How are Fintech and regulatory changes impacting the range of services provided to funds and managers, and what are the VAT implications?
- What’s changing in terms of the collectives themselves, and the different types of vehicles that hold investment assets? What does this mean for exemption and establishment?
- How will (or won’t) any of this be impacted by the end of the Brexit transitional period?
EU Case Law Update
Identifying where businesses are established is essential to any VAT analysis. This session will consider how the domestic courts have approached this in Ocean Finance (UK) and Worms Management Services (France), as well as the CJEU judgment in Dong Yang (establishment via subsidiary).
VAT on employee remuneration continues to create issues, and during the session, we will look at the treatment of staff secondments (San Domenico Vetraria) and a salary sacrifice scheme for a Luxembourg fund manager (QM).
The session will also look ahead to CJEU activity expected over the next year, including DBK (exemption for fund management software), Bank of China (Morgan Stanley revisited), M-GmbH (limited partnerships) and Q-GmbH (insurance intermediation).
AsiaPac Update
The focus of this session will be to provide an update on some of the key regional indirect tax developments in Asia - including the reverse charge in Singapore, the expansion of digital taxes, the potential re-implementation of GST in Malaysia and critical developments in China and India.
From an EU27 perspective, the VAT Directive appears to answer most of the questions relating to supplies of financial services to third countries. However, as businesses change their operating models and new regulatory regimes take effect, the VAT position is still unclear in a number of areas which we will explore. As of the date of preparing this agenda, in the UK there is still no confirmation of the VAT recovery position for exempt supplies made to EU counterparties. Once that decision has been made, there will be a number of areas for FS businesses to get to terms with quickly, including both tax technical and systems issues.
Partial Exemption
There is no doubt that VAT costs are receiving more attention at CFO and board level than ever before and there have been a number of developments in recent times impacting the status quo of partial exemption calculations.
The focus of the session will be around the key global challenges that businesses face around VAT recovery methodologies. The approach and attitude of the tax authorities will drive much of the recovery methodology development by taxpayers and we will explore these different approaches and the attitude of the tax authorities in a number of territories.
VAT and Transfer Pricing
The importance of businesses giving consideration to the VAT implications of inter-company transactions priced in-line with transfer pricing (“TP”) principles is increasing. This session will consider:
- How transaction flows disclosed in TP documentation can be identified as single or multiple supplies for VAT purposes;
- The VAT liability of supplies and whether these are aligned with the TP characterisation as set out within an agreement;
- How an ill-considered TP policy can increase the risk of greater indirect tax exposure and impact input tax recovery; and
- The VAT impact associated with potential changes to TP policies that will be looking to address wider economic challenges including COVID-19, industrial nationalism, global tax reform and Brexit.
Middle East VAT
This session will cover a range of regional hot topics that have prompted significant changes for FS and Insurance businesses in the last year. These include recent changes in law, guidance and practice that have impacted these businesses in the UAE, KSA and Bahrain, including the tripling of the standard VAT rate in KSA, and the planned future introduction of VAT in GCC Member States which have not yet implemented their local VAT regime. The session will focus on providing insights learned with working with businesses in the region to ensure the audience has a thorough grasp of market views and activity. It will also cover the tax appeals procedure in the UAE and our experiences helping clients reduce penalties for non-compliance.
Contacts

Gary Campbell
Partner, Tax

Demian De Souza
Partner, Tax

Neil Reeve
Partner, Tax
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