The European Union Directive - DAC6 Under this Directive, intermediaries or business entities are required to report to the tax authority their country of residence any participation in cross border transactions or activity involving another party who is a EU state, satisfying a main benefit tax avoidance test of qualifying as a hallmark. Failure to report accurately and timely generates a substantial penalty. We assist companies in their understanding of whether they have an obligation to report, the information to be supplied and the timeliness of reporting including whether the transaction satisfies the main benefit or has a hallmark. We also work with clients to determine whether they should adopt a software package and if so which package is likely to result in a minimal risks of failing to fully and accurately report TAX REGULATORY COMPLIANCE We also assist clients in fulfilling regulatory tax compliance obligations. In an ever changing world, where tax authorities have enhanced information gathering powers, transparency and accuracy are paramount. Of the many focus areas, some of the more important follow. Beneficial Ownership Registers The UK together with most EU member states now have or are required to establish registers of beneficial ownership. All British Overseas Territories and Crown Dependencies will introduce public registers for companies, likely by the end of 2020. We advise individuals and entities on the countries which maintain beneficial ownership registers for companies, properties and land, and trusts and the information held on the beneficial ownership within those registers which is publicly available. We also assist individual entities to understand the significance for them of that information becoming public. Economic Substance Regulations Reporting under the economic substance regulations is designed to identify those companies which have insufficient nexus to the country of incorporation to be seen as being able to generate income from the business activities carried on in that jurisdiction. We advise companies on whether they are obligated to report and the relevance for that purpose of the core income generating activities, directed and management and adequate tests. Of particular interest to companies are the relevance of the different reporting requirements for pure holding, IP and the other companies and we advise on whether the companies have fulfilled their obligations and if not, the correcting steps to be undertaken to ensure compliance. Automatic Exchange of Information FATCA and CRS Under these rules financial institutions are required to provide defined information to the taxation authority in the country of that institution’s business on individuals and entities with accounts in that country. This information is then passed on by the taxation authority to the country in which the individual or entity is resident for taxation purposes. We advise individuals and entities on the information which is collected on them, the countries having legal frameworks and working procedures in place to share the information, and the tax residence definitions applied in the FATCA and CRS rules which determine to which country the information is to be reported. Tax for IFRS Companies preparing their annual financial statements under IFRS are required to provide their auditors with a summary of any uncertain taxation positions taken in the financial statements and whether on full disclosure of the transaction or behaviour to the taxation authority that it is probable the authority would agree with the company’s position. Auditors become aware of the potentially uncertain tax positions through a so called IFRIC 23 statement provided by the company. We assist in the preparation of, or review the company’s IFRIC 23 statement including assisting in or advising on whether the ‘probable’ test would be met and the potentially consequences for the company’s financial statements of the probable test not being met. Corruption and Anti-Bribery Companies especially when engaged in international business, are required not only to be in compliance with the range of local anti-corruption regulations (including anti-bribery (FCPA, UKBA), anti-money laundering and sanctions - including PEPs’) but are also bound by regulations of other nations with potential overlapping jurisdictions. Non-compliance could lead to investigations, fines or even ceasing to operate. We will advise on the best strategies suited to the requirement/s of each entity to be compliant and even help with periodic reviews to minimise the risks arising from non-compliance. Published Tax Strategies The UK requires the publication of a tax strategy by a UK group, sub-group, company or partnership, in the circumstances in which in the previous financial year that group had one or both of turnover above £200 million or balance sheet over £2 billion. UK companies or groups which are members of a MNE group that meets the OECD’s ‘Country-by-Country Reporting’ framework threshold of global turnover over €750m also are required to publish a strategy. We advise UK companies and the groups of which they are members on whether they are required to prepare and publish a strategy, and if so, the contents of that strategy. We assist the company in preparing or reviewing its strategy.’

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The European Union Directive - DAC6 Under this Directive, intermediaries or business entities are required to report to the tax authority their country of residence any participation in cross border transactions or activity involving another party who is a EU state, satisfying a main benefit tax avoidance test of qualifying as a hallmark. Failure to report accurately and timely generates a substantial penalty. We assist companies in their understanding of whether they have an obligation to report, the information to be supplied and the timeliness of reporting including whether the transaction satisfies the main benefit or has a hallmark. We also work with clients to determine whether they should adopt a software package and if so which package is likely to result in a minimal risks of failing to fully and accurately report TAX REGULATORY COMPLIANCE We also assist clients in fulfilling regulatory tax compliance obligations. In an ever changing world, where tax authorities have enhanced information gathering powers, transparency and accuracy are paramount. Of the many focus areas, some of the more important follow. Beneficial Ownership Registers The UK together with most EU member states now have or are required to establish registers of beneficial ownership. All British Overseas Territories and Crown Dependencies will introduce public registers for companies, likely by the end of 2020. We advise individuals and entities on the countries which maintain beneficial ownership registers for companies, properties and land, and trusts and the information held on the beneficial ownership within those registers which is publicly available. We also assist individual entities to understand the significance for them of that information becoming public. Economic Substance Regulations Reporting under the economic substance regulations is designed to identify those companies which have insufficient nexus to the country of incorporation to be seen as being able to generate income from the business activities carried on in that jurisdiction. We advise companies on whether they are obligated to report and the relevance for that purpose of the core income generating activities, directed and management and adequate tests. Of particular interest to companies are the relevance of the different reporting requirements for pure holding, IP and the other companies and we advise on whether the companies have fulfilled their obligations and if not, the correcting steps to be undertaken to ensure compliance. Automatic Exchange of Information FATCA and CRS Under these rules financial institutions are required to provide defined information to the taxation authority in the country of that institution’s business on individuals and entities with accounts in that country. This information is then passed on by the taxation authority to the country in which the individual or entity is resident for taxation purposes. We advise individuals and entities on the information which is collected on them, the countries having legal frameworks and working procedures in place to share the information, and the tax residence definitions applied in the FATCA and CRS rules which determine to which country the information is to be reported. Tax for IFRS Companies preparing their annual financial statements under IFRS are required to provide their auditors with a summary of any uncertain taxation positions taken in the financial statements and whether on full disclosure of the transaction or behaviour to the taxation authority that it is probable the authority would agree with the company’s position. Auditors become aware of the potentially uncertain tax positions through a so called IFRIC 23 statement provided by the company. We assist in the preparation of, or review the company’s IFRIC 23 statement including assisting in or advising on whether the ‘probable’ test would be met and the potentially consequences for the company’s financial statements of the probable test not being met. Corruption and Anti-Bribery Companies especially when engaged in international business, are required not only to be in compliance with the range of local anti-corruption regulations (including anti-bribery (FCPA, UKBA), anti-money laundering and sanctions - including PEPs’) but are also bound by regulations of other nations with potential overlapping jurisdictions. Non-compliance could lead to investigations, fines or even ceasing to operate. We will advise on the best strategies suited to the requirement/s of each entity to be compliant and even help with periodic reviews to minimise the risks arising from non-compliance. Published Tax Strategies The UK requires the publication of a tax strategy by a UK group, sub-group, company or partnership, in the circumstances in which in the previous financial year that group had one or both of turnover above £200 million or balance sheet over £2 billion. UK companies or groups which are members of a MNE group that meets the OECD’s ‘Country-by-Country Reporting’ framework threshold of global turnover over €750m also are required to publish a strategy. We advise UK companies and the groups of which they are members on whether they are required to prepare and publish a strategy, and if so, the contents of that strategy. We assist the company in preparing or reviewing its strategy.’
The European Union Directive - DAC6 Under this Directive, intermediaries or business entities are required to report to the tax authority their country of residence any participation in cross border transactions or activity involving another party who is a EU state, satisfying a main benefit tax avoidance test of qualifying as a hallmark. Failure to report accurately and timely generates a substantial penalty. We assist companies in their understanding of whether they have an obligation to report, the information to be supplied and the timeliness of reporting including whether the transaction satisfies the main benefit or has a hallmark. We also work with clients to determine whether they should adopt a software package and if so which package is likely to result in a minimal risks of failing to fully and accurately report TAX REGULATORY COMPLIANCE We also assist clients in fulfilling regulatory tax compliance obligations. In an ever changing world, where tax authorities have enhanced information gathering powers, transparency and accuracy are paramount. Of the many focus areas, some of the more important follow. Beneficial Ownership Registers The UK together with most EU member states now have or are required to establish registers of beneficial ownership. All British Overseas Territories and Crown Dependencies will introduce public registers for companies, likely by the end of 2020. We advise individuals and entities on the countries which maintain beneficial ownership registers for companies, properties and land, and trusts and the information held on the beneficial ownership within those registers which is publicly available. We also assist individual entities to understand the significance for them of that information becoming public. Economic Substance Regulations Reporting under the economic substance regulations is designed to identify those companies which have insufficient nexus to the country of incorporation to be seen as being able to generate income from the business activities carried on in that jurisdiction. We advise companies on whether they are obligated to report and the relevance for that purpose of the core income generating activities, directed and management and adequate tests. Of particular interest to companies are the relevance of the different reporting requirements for pure holding, IP and the other companies and we advise on whether the companies have fulfilled their obligations and if not, the correcting steps to be undertaken to ensure compliance. Automatic Exchange of Information FATCA and CRS Under these rules financial institutions are required to provide defined information to the taxation authority in the country of that institution’s business on individuals and entities with accounts in that country. This information is then passed on by the taxation authority to the country in which the individual or entity is resident for taxation purposes. We advise individuals and entities on the information which is collected on them, the countries having legal frameworks and working procedures in place to share the information, and the tax residence definitions applied in the FATCA and CRS rules which determine to which country the information is to be reported. Tax for IFRS Companies preparing their annual financial statements under IFRS are required to provide their auditors with a summary of any uncertain taxation positions taken in the financial statements and whether on full disclosure of the transaction or behaviour to the taxation authority that it is probable the authority would agree with the company’s position. Auditors become aware of the potentially uncertain tax positions through a so called IFRIC 23 statement provided by the company. We assist in the preparation of, or review the company’s IFRIC 23 statement including assisting in or advising on whether the ‘probable’ test would be met and the potentially consequences for the company’s financial statements of the probable test not being met. Corruption and Anti-Bribery Companies especially when engaged in international business, are required not only to be in compliance with the range of local anti-corruption regulations (including anti-bribery (FCPA, UKBA), anti-money laundering and sanctions - including PEPs’) but are also bound by regulations of other nations with potential overlapping jurisdictions. Non-compliance could lead to investigations, fines or even ceasing to operate. We will advise on the best strategies suited to the requirement/s of each entity to be compliant and even help with periodic reviews to minimise the risks arising from non-compliance. Published Tax Strategies The UK requires the publication of a tax strategy by a UK group, sub-group, company or partnership, in the circumstances in which in the previous financial year that group had one or both of turnover above £200 million or balance sheet over £2 billion. UK companies or groups which are members of a MNE group that meets the OECD’s ‘Country-by-Country Reporting’ framework threshold of global turnover over €750m also are required to publish a strategy. We advise UK companies and the groups of which they are members on whether they are required to prepare and publish a strategy, and if so, the contents of that strategy. We assist the company in preparing or reviewing its strategy.’
The European Union Directive - DAC6 Under this Directive, intermediaries or business entities are required to report to the tax authority their country of residence any participation in cross border transactions or activity involving another party who is a EU state, satisfying a main benefit tax avoidance test of qualifying as a hallmark. Failure to report accurately and timely generates a substantial penalty. We assist companies in their understanding of whether they have an obligation to report, the information to be supplied and the timeliness of reporting including whether the transaction satisfies the main benefit or has a hallmark. We also work with clients to determine whether they should adopt a software package and if so which package is likely to result in a minimal risks of failing to fully and accurately report TAX REGULATORY COMPLIANCE We also assist clients in fulfilling regulatory tax compliance obligations. In an ever changing world, where tax authorities have enhanced information gathering powers, transparency and accuracy are paramount. Of the many focus areas, some of the more important follow. Beneficial Ownership Registers The UK together with most EU member states now have or are required to establish registers of beneficial ownership. All British Overseas Territories and Crown Dependencies will introduce public registers for companies, likely by the end of 2020. We advise individuals and entities on the countries which maintain beneficial ownership registers for companies, properties and land, and trusts and the information held on the beneficial ownership within those registers which is publicly available. We also assist individual entities to understand the significance for them of that information becoming public. Economic Substance Regulations Reporting under the economic substance regulations is designed to identify those companies which have insufficient nexus to the country of incorporation to be seen as being able to generate income from the business activities carried on in that jurisdiction. We advise companies on whether they are obligated to report and the relevance for that purpose of the core income generating activities, directed and management and adequate tests. Of particular interest to companies are the relevance of the different reporting requirements for pure holding, IP and the other companies and we advise on whether the companies have fulfilled their obligations and if not, the correcting steps to be undertaken to ensure compliance. Automatic Exchange of Information FATCA and CRS Under these rules financial institutions are required to provide defined information to the taxation authority in the country of that institution’s business on individuals and entities with accounts in that country. This information is then passed on by the taxation authority to the country in which the individual or entity is resident for taxation purposes. We advise individuals and entities on the information which is collected on them, the countries having legal frameworks and working procedures in place to share the information, and the tax residence definitions applied in the FATCA and CRS rules which determine to which country the information is to be reported.
Tax for IFRS Companies preparing their annual financial statements under IFRS are required to provide their auditors with a summary of any uncertain taxation positions taken in the financial statements and whether on full disclosure of the transaction or behaviour to the taxation authority that it is probable the authority would agree with the company’s position. Auditors become aware of the potentially uncertain tax positions through a so called IFRIC 23 statement provided by the company. We assist in the preparation of, or review the company’s IFRIC 23 statement including assisting in or advising on whether the ‘probable’ test would be met and the potentially consequences for the company’s financial statements of the probable test not being met.
Corruption and Anti-Bribery Companies especially when engaged in international business, are required not only to be in compliance with the range of local anti-corruption regulations (including anti-bribery (FCPA, UKBA), anti-money laundering and sanctions - including PEPs’) but are also bound by regulations of other nations with potential overlapping jurisdictions. Non-compliance could lead to investigations, fines or even ceasing to operate. We will advise on the best strategies suited to the requirement/s of each entity to be compliant and even help with periodic reviews to minimise the risks arising from non-compliance.
Published Tax Strategies The UK requires the publication of a tax strategy by a UK group, sub-group, company or partnership, in the circumstances in which in the previous financial year that group had one or both of turnover above £200 million or balance sheet over £2 billion. UK companies or groups which are members of a MNE group that meets the OECD’s ‘Country-by-Country Reporting’ framework threshold of global turnover over €750m also are required to publish a strategy. We advise UK companies and the groups of which they are members on whether they are required to prepare and publish a strategy, and if so, the contents of that strategy. We assist the company in preparing or reviewing its strategy.’
The European Union Directive - DAC6 Under this Directive, intermediaries or business entities are required to report to the tax authority their country of residence any participation in cross border transactions or activity involving another party who is a EU state, satisfying a main benefit tax avoidance test of qualifying as a hallmark. Failure to report accurately and timely generates a substantial penalty. We assist companies in their understanding of whether they have an obligation to report, the information to be supplied and the timeliness of reporting including whether the transaction satisfies the main benefit or has a hallmark. We also work with clients to determine whether they should adopt a software package and if so which package is likely to result in a minimal risks of failing to fully and accurately report TAX REGULATORY COMPLIANCE We also assist clients in fulfilling regulatory tax compliance obligations. In an ever changing world, where tax authorities have enhanced information gathering powers, transparency and accuracy are paramount. Of the many focus areas, some of the more important follow. Beneficial Ownership Registers The UK together with most EU member states now have or are required to establish registers of beneficial ownership. All British Overseas Territories and Crown Dependencies will introduce public registers for companies, likely by the end of 2020. We advise individuals and entities on the countries which maintain beneficial ownership registers for companies, properties and land, and trusts and the information held on the beneficial ownership within those registers which is publicly available. We also assist individual entities to understand the significance for them of that information becoming public. Economic Substance Regulations Reporting under the economic substance regulations is designed to identify those companies which have insufficient nexus to the country of incorporation to be seen as being able to generate income from the business activities carried on in that jurisdiction. We advise companies on whether they are obligated to report and the relevance for that purpose of the core income generating activities, directed and management and adequate tests. Of particular interest to companies are the relevance of the different reporting requirements for pure holding, IP and the other companies and we advise on whether the companies have fulfilled their obligations and if not, the correcting steps to be undertaken to ensure compliance. Automatic Exchange of Information FATCA and CRS Under these rules financial institutions are required to provide defined information to the taxation authority in the country of that institution’s business on individuals and entities with accounts in that country. This information is then passed on by the taxation authority to the country in which the individual or entity is resident for taxation purposes. We advise individuals and entities on the information which is collected on them, the countries having legal frameworks and working procedures in place to share the information, and the tax residence definitions applied in the FATCA and CRS rules which determine to which country the information is to be reported.
Tax for IFRS Companies preparing their annual financial statements under IFRS are required to provide their auditors with a summary of any uncertain taxation positions taken in the financial statements and whether on full disclosure of the transaction or behaviour to the taxation authority that it is probable the authority would agree with the company’s position. Auditors become aware of the potentially uncertain tax positions through a so called IFRIC 23 statement provided by the company. We assist in the preparation of, or review the company’s IFRIC 23 statement including assisting in or advising on whether the ‘probable’ test would be met and the potentially consequences for the company’s financial statements of the probable test not being met. Corruption and Anti-Bribery Companies especially when engaged in international business, are required not only to be in compliance with the range of local anti-corruption regulations (including anti-bribery (FCPA, UKBA), anti-money laundering and sanctions - including PEPs’) but are also bound by regulations of other nations with potential overlapping jurisdictions. Non-compliance could lead to investigations, fines or even ceasing to operate. We will advise on the best strategies suited to the requirement/s of each entity to be compliant and even help with periodic reviews to minimise the risks arising from non-compliance. Published Tax Strategies The UK requires the publication of a tax strategy by a UK group, sub-group, company or partnership, in the circumstances in which in the previous financial year that group had one or both of turnover above £200 million or balance sheet over £2 billion. UK companies or groups which are members of a MNE group that meets the OECD’s ‘Country-by-Country Reporting’ framework threshold of global turnover over €750m also are required to publish a strategy. We advise UK companies and the groups of which they are members on whether they are required to prepare and publish a strategy, and if so, the contents of that strategy. We assist the company in preparing or reviewing its strategy.’