ALIGNING ECONOMIC SUBSTANCE AND TAX ESTAR: ECONOMIC SUBSTANCE TAX REVIEW

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1 ALIGNING ECONOMIC SUBSTANCE AND TAX ESTAR: ECONOMIC SUBSTANCE TAX REVIEW

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3 estar: economic substance review 01 ALIGNING ECONOMIC SUBSTANCE AND TAX ECONOMIC SUBSTANCE IS VITALLY IMPORTANT FOR TAX - IT IS THE SINGLE MOST IMPORTANT FACTOR IN DETERMINING THE TAXABLE PROFITS OF A GROUP. Ensuring that tax liabilities reflect the economic substance of a business has been the main area of focus for the OECD s BEPS initiative and will be a key driver for tax authorities enquiries going forward. This will have huge implications for transfer pricing but it will also be critical in many other tax areas that affect international groups including: residence treaty benefits nexus permanent establishment vat and customs duty THE RISK WHEN ECONOMIC SUBSTANCE DOES NOT MATCH YOUR TAX POLICY Tax authorities are increasingly focused on how a business model works and its tax implications not just its legal framework. Businesses are constantly evolving, so if you don t pay attention to alignment of economic substance and tax it can significantly increase your tax risk in a number of areas. BDO s ESTAR service provides a structured and systematic review to identify areas where insufficient economic substance creates tax risks. Our experts use recognised tools such as a RACI analysis to evaluate the economic substance of a group and give clear advice on areas where there are concerns. WHAT IS ECONOMIC SUBSTANCE? Economic substance encompasses the functions, assets and risks of a business, together with the management of these activities. In particular, the focus is on those activities which play a leading role in value creation. In most cases, the structure of activities and location of their management will be clear cut, but sometimes more detailed analysis will be needed. For example, for intellectual property, the OECD recommends separate consideration of the development, enhancement, maintenance, protection and exploitation of the asset(s). TAX AUTHORITY ACTION When examining a business, most tax authorities will typically start by looking at its legal substance the corporate structure and framework of agreements between the entities. The OECD s guidelines then require a review of the economic substance. If there is a difference between the two, then the economic substance will take precedence when determining the appropriate tax treatment. A lack of economic substance could lead to a lengthy enquiry if challenged. This challenge could come from the local tax authority, or from another territory, where the fiscal authority perceives that there is a loss of tax revenue so there is a high tax risk associated with this area. Most tax authorities are now focused closely on both international tax arrangements and transfer pricing policies. In this, they have the backing of governments and media that have greatly increased the profile of the issue. The transparency of business arrangements is driven by a number of international developments including FATCA and the Common Reporting Standard, the introduction of country-by-country reporting for qualifying groups and the creation of company beneficial owner registers. Together, these will dramatically increase information sharing amongst tax authorities. Pre-empting a tax authority challenge can reduce the risk of lengthy tax audits and enquiries, as well as mitigating the risk of additional tax liabilities, together with penalties and the potential for double taxation. Early action is vital to ensure that there is enough lead time to address any issues either by updating your tax policies to match the current economic substance of your business, or by restructuring your business operations to ensure there is sufficient economic substance to support your existing tax policies.

4 02 estar: economic substance review ALIGNING ECONOMIC SUBSTANCE AND TAX EXAMPLES OF THE POTENTIAL RISKS The location of each function together with its associated value to the business will be tested by tax authorities against the tax and transfer pricing policy used. Local income and profit will need to be clearly consistent with activities and the management of risk to prevent further enquiry and challenge. Common examples of where a challenge may occur include: Where a territory is rewarded at the expense of the location of the relevant management activity If the local management presence is transitory and cannot be clearly shown to exercise its authority in a location (for example a board flying into a meeting where decisions are essentially a rubber stamp of recommendations) Where an entity carrying risk is not in control of that risk something that a third party would not agree to at arm s length Cases where the level of activity in a territory is minimal for example only contracts or pass through costs and insufficient to sustain a ruling or treaty benefits. Instances like this can arise due to policy design, but also where a business has evolved more rapidly than the tax and transfer pricing policy can keep pace with. BEST PRACTICE To mitigate risk of tax authority challenge, your tax and transfer pricing policy should be aligned to your business model. This should be clearly documented to set out both the business policy and support for why it is appropriate. Even if the policy is considered robust, there may be benefit from revisiting the transfer pricing documentation to ensure that key messages are conveyed effectively. information review workshop review of findings outcomes discussion paper policy discussion and agreement initial insights detailed review next steps Initial provision and review of: Organisation chart Group Structure Intercompany agreements HOW BDO CAN HELP BDO has extensive experience working with businesses to understand the key aspects of their business model. BDO s ESTAR is a high level review to understand the key aspects of the business model, identify potential weaknesses in light of BEPS and present our recommendations to the business. Based on these, you can then assess where more detailed work is required, enabling resources to be targeted effectively. Although our review is intended to be high level, we will consider to all the areas which are affected if economic substance does not align with tax and transfer pricing policies. This could include residence status, treaty benefit, nexus and permanent establishments. We approach this using the steps outlined below: Meeting with key personnel to review business model, tax and TP policy High-level functional analysis Using templates provided Assessment of the implications on the business tax and transfer pricing policies Review of risks Consideration of level of risk / priority areas to be addressed Provision of a memo setting out: Findings and comments on current model Recommendations to address weaknesses and opportunities Use of findings to: Agree changes to policy or business model Set out next steps

5 estar: economic substance review 03 WORKSHOP AIMS The workshop aims to map the key functions and risks of the business and the tax and transfer pricing policy. UNDERSTAND THE BUSINESS VALUE CHAIN Title flow Organisational structure IDENTIFY KEY VALUE DRIVERS Intangible assets, eg technical or trademark Tangible assets, eg stock, plant or logistics infrastructure What are the key risks? DETERMINE KEY FUNCTIONS, ASSETS, RISKS AND MANAGEMENT ACTIVITIES Who signs off on decisions or projects? Who performs stage gate reviews? Who develops and maintains key assets? Where do key risks sit, eg warranty risk? Who could get sued, and who mitigates the likelihood? Who provides financing? Can attributes be outsourced? LOCATE THESE ATTRIBUTES BY TERRITORY AND ENTITY FINDINGS Show management decision-making (show no as well as yes ) CONSIDER HOW THESE ATTRIBUTES FIT INTO THE WIDER BUSINESS ORGANISATION Is decision making set up to be practical and achievable? Would (or could) third parties work in this way? TEST WHETHER THEY ARE CONSISTENT WITH Legal framework Tax and transfer pricing policy KEY AREAS UNDER REVIEW INTELLECTUAL PROPERTY For intellectual property, the OECD recommends consideration of the following areas: developing enhancing maintaining protecting exploiting The workshop facilitates a discussion of all the business s key intellectual property, and aims to identify where each of the above activities are taking place. MANAGEMENT RESPONSIBILITY Similarly, when looking in detail at management activity the OECD has suggested performing a RACI analysis, looking at who is: responsible Who delivers the project? Who is relied upon to ensure objectives are met? accountable Who is ultimately accountable for meeting objectives? Who carries the can? consulted Who is consulted for expertise, permission or to achieve buy-in? informed Who is informed of decisions and progress?

6 04 estar: economic substance review ALIGNING ECONOMIC SUBSTANCE AND TAX SAMPLE WORKSHOP MATERIALS REVIEW AND OUTCOMES Following the workshop, we will: Review our findings, where necessary in discussion with our local or subject matter experts Prepare our recommendations in a discussion paper to work through with you - this will include a summary of the potential risks identified and the level of risk to which the business is exposed Work with you to identify changes which may be required. From these steps, changes to either the business model, tax structure or transfer pricing policy may be made, and robust documentation can be put in place. We will be happy to support the business in implementing any changes identified in the review, based on a scope to be identified at the conclusion of the review.

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8 FOR MORE INFORMATION: MALCOLM JOY t: +44 (0) e: PAUL DALY t: +44 (0) e: ANTON HUME t: +44 (0) e: DUNCAN NOTT t: +44 (0) e: This publication has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The publication cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact BDO LLP to discuss these matters in the context of your particular circumstances. BDO LLP, its partners, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it. BDO LLP, a UK limited liability partnership registered in England and Wales under number OC305127, is a member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. A list of members names is open to inspection at our registered office, 55 Baker Street, London W1U 7EU. BDO LLP is authorised and regulated by the Financial Conduct Authority to conduct investment business. BDO is the brand name of the BDO network and for each of the BDO Member Firms. BDO Northern Ireland, a partnership formed in and under the laws of Northern Ireland, is licensed to operate within the international BDO network of independent member firms. May 2016 BDO LLP. All rights reserved

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