The view from Business Diane Hay, PwC

Transcription

1 The view from Business Diane Hay,

2 My background Tax inspector with Inland Revenue/ HMRC most of my working life largely in international tax Involved with OECD for over 20 years first President of Working Group that eventually produced the 1995 TP Guidelines, but also worked on 2010 revision From 2004 to 2008 head of TP at HMRC, led the Transfer Pricing Group, and head of APA and MAP programmes From 2009 at, working with many global businesses with special emphasis on dispute resolution, APAs and MAP work Particular interest in APA programmes in BRICs and developing world Slide 2

3 Key issues for business Greater consistency and stability of rules Fit for purpose and based on the arm s length standard Good relationships with tax authorities Built on trust and integrity At various levels both head office and field More certainty of outcomes How rules will be applied in practice Likely areas of concern for tax authorities Advance rulings and APAs Slide 3

4 Key issues for business Better and sustained capability Tax authority people who are trained in TP issues, including an understanding of business And who are able to develop increasing understanding of TP issues through their experience Effective dispute resolution A good process for resolving disputes Consultation Opportunity to comment on changes before they are made Slide 4

5 Why business wants to support TP in developing countries The business case Business is very keen to build relationships and TP expertise in developing countries A better relationship flows through into a better environment for investment A better investment environment leads to increased investment, more profits and more tax being paid Slide 5

6 How Business could support this taskforce Better relationships Building long-lasting and good relationships with key stakeholders in tax authorities at all relevant levels Showing how this has been achieved in other countries Being a champion for the Taskforce and raising its profile with their clients and customers Slide 6

7 How Business could support this taskforce? Greater expertise By helping to build business expertise and TP knowledge Creating opportunities for tax authority officials to meet with people from business Seconding their own people to work within tax authorities to lead specific projects or to act as general advisers Fostering effective dispute resolution through adapting tools used elsewhere Slide 7

8 How Business could support this taskforce Willingness to fund I believe business may be willing to fund tax authorities to build their capacity and capability - By sharing knowledge on how business works, not just from the tax side - Helping to train tax inspectors and auditors - Helping them to develop ways to administer and organise TP work within a tax authority - Sharing their experiences of good practice Slide 8

9 Diane Hay This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its members, employees and agents do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it. <YEAR HERE> PricewaterhouseCoopers LLP. All rights reserved. In this document, refers to PricewaterhouseCoopers LLP (a limited liability partnership in the United Kingdom) which is a member firm of PricewaterhouseCoopers International Limited, each member firm of which is a separate legal entity.