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Global Financial Services and Insurance Indirect Tax Conference

A world of change

1 - 3 December 2020
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Conference agenda

  • Agenda
    Day 1

     

  • Agenda
    Day 2

     

  • Agenda
    Day 3

     

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.

How in-house Tax and Finance teams structure themselves and function has a significant impact on their performance and effectiveness. This session will explore what factors impact this effectiveness, focusing on:

  • roles and processes;
  • maximising scope for automation;
  • use of shared service centres and finance support; and
  • the scope for outsourcing compliance and tax functions more widely;

Tactical Automation and Enabling Technologies
As digital reporting requirements expand across the globe, this session will provide a spotlight on the tactical automation technologies that enable you to move up the digital maturity curve, and help support your transformation ambitions.

This breakout session will aim to get viewpoints from participants on the drivers important to you, the technologies that are out there, as well as how to build your business case.

Penalties and Disputes
Post COVID-19 economic difficulties mean that tax authorities are under pressure to raise revenues through all means possible. This has resulted in an increased threat of penalties in situations previously not seen. Penalties are a significant cost for businesses and related discussions with tax authorities need to be carefully managed. This session will highlight recent developments, including challenging the penalty quantum, providing mitigating factors and navigating penalty issues more generally. We will also give an overview of how different EMEA tax authorities are using this tool in conjunction with their assessment powers.

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.

ERP Implementation
“Where do I start with an ERP implementation?”

We will discuss the features, benefits and opportunities that various ERP systems present for financial services, and how to approach an implementation from a tax function perspective. We will also cover how to shape a tax business case, what a ‘phase 0’ looks like and the tax role within it, and how to plan for the further stages of the implementation.

The payments revolution:

Technology continues to disrupt the payments market, with card transactions beginning to overtake cash in most major markets and this has been exacerbated by the COVID-19 pandemic.

In this session, we will look at how changes in consumer, retailer and tax authority behaviour has impacted the market (and the associated indirect tax consequences), including how:

  • The payments ecosystem has evolved;
  • Tax authority measures are targeting the payment providers as a tax collection/reporting measure; and
  • Online platforms are utilising virtual currencies to enhance user experience.

Fintech and Insurtech
FinTech disruption:

Since the last financial crisis, regulators have taken steps to open up the financial services and insurance markets to new, tech-enabled operators seeking to build out user-centric business models. In this session, we will consider some of these models, their unique selling points and the resulting indirect tax implications arising, including:

  • Digital/open banking and monetisation of data;
  • Use of artificial intelligence to automate process and democratise access; and
  • Blockchain technology and cryptoassets.

Insurance
During this breakout session, a panel of insurance specialists from the UK, Germany, the Netherlands and Denmark will provide insight and analysis in respect of the following:

  • The IPT location of risk rules in the EU and how to navigate this complex landscape; and
  • Tax authority challenges and the complexity of achieving VAT efficient outsourcing for services in the insurance sector.

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.

Contacts

Gary Campbell

Gary Campbell

Partner, Tax

Demian De Souza

Demian De Souza

Partner, Tax

Neil Reeve

Neil Reeve

Partner, Tax

Tom Jacobs

Tom Jacobs

Partner, Tax

Pete White

Peter White

Partner, Tax

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