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Study visit Inland Revenue Service of Chili

Study visit Inland Revenue Service of Chili. 20 & 21 november 2007. BIENVENUDOS. Hans Rouw ja.rouw@belastingdienst.nl Tom Quelle t.quelle@belastingdiemst.nl Dutch Tax and Customs Administration Belastingdienst Amsterdam. Amsterdam.

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Study visit Inland Revenue Service of Chili

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  1. Study visit Inland Revenue Service of Chili 20 & 21 november 2007 BIENVENUDOS Hans Rouw ja.rouw@belastingdienst.nl Tom Quelle t.quelle@belastingdiemst.nl Dutch Tax and Customs Administration Belastingdienst Amsterdam Amsterdam nov 20 and 21

  2. Dutch Tax and Customs Administration=Belastingdienst nov 20 and 21

  3. Welcome in Amsterdam 20 & 21 november 2007 nov 20 and 21

  4. More than 200 year experience with taxation • Advantages but also disadvantages • Constantly changing environment: so a constantly changing organisation • Laws that are political instruments • Entering the “E-world” nov 20 and 21

  5. WWW.Belastingdienst.nl • All kind of public information on the web site. • In the future everyone a “personal status site” nov 20 and 21

  6. The Netherlands Economic activities Clogs, Tulips and Windmills nov 20 and 21

  7. Europe - European Union. • Old members New mebers • Potential members • Waiting-room nov 20 and 21

  8. The Netherlands • Over 16 million inhabitants • 1.000.000 enterprises (MKB) • 10.000 large organisations (MGO) • 1.000 very large organisations (ZGO) • 25 global players (ZGO) • import/export country • (small) financial center in Europe • large continental shelf • many taxes and tax-treaties nov 20 and 21

  9. Summary of Taxes in The Netherlands • Taxes on income, profits and net wealth • Taxes and duties on goods and services • Social security contributions nov 20 and 21

  10. Income, profit, net wealth Income tax Corporate tax Dividend tax Inheritance tax Salaries tax Tax on games and chance Goods and services VAT Import duty Insurance tax Motor vihicle tax Environmental tax Regulatory energy tax Dutch Taxation nov 20 and 21

  11. Difference between commercial annual report and fiscal report. • Commercial annual report on basis of international financial reporting standards (IFRS) or Dutch accountanting/auditing standards. • Annual fiscal report on basis of fiscal legislation and fiscal rules. • Requirements SEC (US-GAAP) • AFM nov 20 and 21

  12. Accounting, Auditing and Tax-advisor • Every enterprise in the Netherlands has its own tax-advisor. • Bookkeeping and accounting mostly “in house” or with the support of specialist. • External auditing only in large companies. nov 20 and 21

  13. The government in The Hague nov 20 and 21

  14. Dutch National Bank nov 20 and 21

  15. Ministery of Finance nov 20 and 21

  16. The Top mr. K-J. de Jager mr. W. Bos Minister of finance State-secretary for tax and customs mrs. Thunnissen Director general Belastingdienst nov 20 and 21

  17. The Dutch Treat Tax and Customs Administration of The Netherlands Belastingdienst / Amsterdam nov 20 and 21

  18. Integrated Tax and Customs organisation 13 regional tax-offices 4 regional customs-offices nov 20 and 21

  19. Dutch Tax and Customs Org. nov 20 and 21

  20. Belastingdienst / Regions Tax organisation of The Netherlands 1. Noord 2. Oost 3. Randmeren 4. Rivierenland 5. Utrecht-Gooi 6. Amsterdam 7. Holland Noord 8. Haaglanden 9. Holland Midden 10. Rijnmond 11. Zuidwest 12. Oost-Brabant 13. Limburg nov 20 and 21

  21. Two main offices for very large organisations Rotterdam Amsterdam nov 20 and 21

  22. Belastingdienst/Regions of customs 1. WEST 2. ROTTERDAM 3. North 4. South nov 20 and 21

  23. General policy statements Dutch Tax and Customs Administration • promotion of compliance • communication with and service to taxpayers • from D-service to E-service • uphold (tax-)laws • unity in performance nov 20 and 21

  24. Compliance policy Wanted effect: compliance Content of legislation Investigation & monitoring (intelligence) Agreements Co-ordination Maintaining Compliance Communication Actions an themes Administrative supervision Specific investigations Fraud investigations Interactive nov 20 and 21

  25. Pyramid of supervision ‘Opsporing’ High risk intensive supervision mass supervision information service CRM Low risk nov 20 and 21

  26. Difference in treatment between individuals and companies • Treatment of individuals is highly automated (internet) • Treatment of small companies will be automated in the next 5 years. • Complicated fiscal legislation for companies • Administrative obligations for companies • Roll of tax advisor and tax auditor nov 20 and 21

  27. Dutch Global Players • Royal Dutch Shell • Ahold • Akzo Nobel • KPN Telecom • Unilever • ING • ABNAMRO • Philips • Heineken • Air France KLM • Corus • Dutch State Mines • Sara Lee nov 20 and 21

  28. Cash cow >50% of the total Dutch tax revenue is generated by very large taxpayers nov 20 and 21

  29. Special treatment • Very large companies • Bank companies • Insurance companies • Stockexchange service • Energy companies • Oil & gas companies • Football organisations • Advance rulings nov 20 and 21

  30. Tax Rulings History • 1989 local ruling taxinspector • 1990 concentration rulingtaxinspectors in Rotterdam • 1997 EU Harmfull taxcompetitionreport • 2001 APA/ ATR practice nov 20 and 21

  31. APA/ATR practiceAPA = advance pricing agreementATR= advance tax ruling • Concentration in Rotterdam • Important role for knowledge group (CGVP) • Codification of the “arm’s length priciple” • Obligation for transparant documentation • Some new legislation • Study of substance rules in tax havens • Taylor made agreements nov 20 and 21

  32. Knowledge groups • Fiscal-law knowledge groups • “Combat groups” against (tax avoidance/evasion) • Co-ordination of actions against fraud • Knowledgegroup for very large organisations nov 20 and 21

  33. 800 experts handling very large organisations • Tax inspectors • Tax auditors • Tax collectors • Client co-ordinators • Managers • Administrative support nov 20 and 21

  34. 3 levels in education • 1. University (external) • 2. Intermediate (internal) • 3. Lower (internal) nov 20 and 21

  35. Process of selection: orientation in 2 directions • Mass production • only special risks & selected risks for small companies and individuals • Tailor-made production • complex companies & very large companies nov 20 and 21

  36. Tailor-made productionvery large enterprises • Central role of the accountmanager / client co-ordinator • Try to make a convenant • Tailor-made risk finding • Support bij an information system (ATK) • Plan of handling nov 20 and 21

  37. Selection process “tailor-made” Two steps: • Co-ordinator (spider) • analyses the risks of his/her clients • Selection team • negotiating about risks that have to be handled • deviation of risks between specialists Role of the “ATK “ (information)system nov 20 and 21

  38. Audit-plan large enterprises • Based on the plan of handling • Tax control framework • Risk oriented approach • Partial or full audit • EDP assisted nov 20 and 21

  39. Role of the co-ordinator • Initiator • Match-maker between specialists and company • Negotiator • Specialist in own discipline ( b.e. transferpricingaudits) • Communication problem solver “The one everyone can blame if something goes wrong” nov 20 and 21

  40. Preliminary consultations • Special rules and instructions for tax rulings. • European demension nov 20 and 21

  41. New developments • Convenants with very large organisations nov 20 and 21

  42. The End nov 20 and 21

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