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International Tax Review - 2015 Financial Services Industry guide
International Tax Review published its inaugural financial services industry guide, in association with Deloitte, analyzing the tax and transfer pricing implications for taxpayers operating across the financial services industry. In this guide, we provide valuable insights into some of the most significant challenges that financial institutions are likely to come across in connection with international taxation, as well as updates on the status of some transfer pricing initiatives that will affect FSI multinationals.
2015 Financial Services Industry guide
The 2015 guide is comprised of seven different articles written by Deloitte tax professionals from around the globe.
Recent international transfer pricing developments in the financial services industry
Deloitte’s UK transfer pricing practice recently held a seminar for its clients in the financial services sector. As part of this event, representatives from Deloitte’s financial services transfer pricing practices provided updates on key events in their respective markets. Below is a summary of each of the presentations from the London event, by Bill Yohana of Deloitte in the US.
Application of the AOA for PEs of banks and insurance companies in Germany
Oliver Busch and Jobst Wilmanns, of Deloitte Germany, take a look at the authorised OECD approach for PEs of banks and insurance companies in Germany.
Risk & recharacterisation
Risk and recharacterisation – Does it make sense in a financial services context?
Robert Plunkett, Bill Yohana, and Brian Green of Deloitte Tax in the US, focus on the aspects of risk and recharacterisation and explain how taxpayers can take measure to protect themselves as global legislation realigns.
New powers to tax offshore booking of Australian customer sales
Geoff Gill and Priscilla Ratilal, of Deloitte Australia, discuss the Australian government’s increased focus on anti-avoidance measures to tax offshore bookings of Australian customer sales, particularly in relation to marketing operations.
How BEPS and and Bulletin 16 could impact outbound payments from China
Patrick Cheung and Johnny Foun, of Deloitte China, go through the significant aspects of the BEPS action plan and local legislation to explore how these policies could affect multinationals’ outbound payments from China.
Unfolding the transfer pricing complexities in Indian financial services
Anis Chakravarty, Vineet Chhabra and Neha Bang of Deloitte India discuss how the transfer pricing aspects of the financial services industry have developed and what taxpayers can expect next.
PE issues in global insurance distribution
Sebastian Ma’ilei & Jeremy Brown, of Deloitte UK, describe how permanent establishment issues can arise from global insurance distribution models and explain how taxpayers can prepare and defend themselves.