The Future of Tax Practice BKR Worldwide Meeting Dublin , Ireland 2013

1. The Future of Tax Practice BKR Worldwide Meeting Dublin, Ireland 2013 European Fiscal Services Ltd ian.hayes@e-fisc.com

2. The Future of Tax Practice 2013 Ian E Hayes FCA FIIT CTA FRSA Vice President C.F.E. Consultant Tax Adviser European Fiscal Services Ltd ian.hayes@e-fisc.com

3. Our Time Today • Highlights of the millennium years • Current Drivers • The Next 2 years • Tax Practice of the future • Discussion points European Fiscal Services Ltd ian.hayes@e-fisc.com

4. 2001 -2013 - 1 • Client Relations • Software developments • Professional • State sponsored • Old methods new problems • Pressure on fees European Fiscal Services Ltd ian.hayes@e-fisc.com

5. 2001 -2013 - 2 • Anti Money laundering • Regulation and Competition • Tax Avoidance/Abuse • Ethics • Client expectation • State reaction • The need to invest European Fiscal Services Ltd ian.hayes@e-fisc.com

6. 2001 -2013 - • ECONOMIC CRASH European Fiscal Services Ltd ian.hayes@e-fisc.com

7. Current Drivers - 1 • G8 to G20 • Revenue Authorities • OECD • Tax Activists and NFPs • Highly visible corporate planning • The Politics of tax havens European Fiscal Services Ltd ian.hayes@e-fisc.com

8. Current Drivers - 2 • BEPS • Base Erosion and Profit Shifting • OECD Global Tax Forum • Automatic exchange of information • OECD 15 point plan • G20 plus 16 committed to reform of global taxation model European Fiscal Services Ltd ian.hayes@e-fisc.com

9. Current Drivers - 3 • The search for • Transparency • Consistency • Certainty • Tax “fairness” European Fiscal Services Ltd ian.hayes@e-fisc.com

10. Finished by September 2014? • The Digital Economy • Prevent Treaty Abuse • Neutralise hybrid mismatch arrangements • Prevent the artificial avoidance of P.E. Status • Re-examine transfer pricing documentation European Fiscal Services Ltd ian.hayes@e-fisc.com

11. December 2014 – In Progress To complete by September 2015 ? • Counter harmful tax practices transparency and substance • Transfer pricing outcomes in line with intangible value creation • Develop a multilateral instrument European Fiscal Services Ltd ian.hayes@e-fisc.com

12. Finished by September 2015 ? • Strengthen CFC rules • Limit base erosion by interest and other financial payments • Transfer pricing outcomes in line with risk and capital value creation • Transfer pricing outcomes in line with other high risk transaction value creation • Methods to collect and analyse BEPS data – actions to address • Disclosure of aggressive tax planning by taxpayers • Effective dispute resolution mechanisms European Fiscal Services Ltd ian.hayes@e-fisc.com

13. The Global Tax Forum Automatic bilateral exchange of information European Fiscal Services Ltd ian.hayes@e-fisc.com

14. Tax Practice in the Future – 1 Bread and butter issues • Compliance • Risk management • Client • Authority • Staff • Tax in a changing environment European Fiscal Services Ltd ian.hayes@e-fisc.com

15. Tax Practice in the Future – 2 Expenditure and Investment • Training • Software • Practice assured European Fiscal Services Ltd ian.hayes@e-fisc.com

16. Tax Practice in the Future – 3 Good boy syndrome • Tax Planning for clients • Avoidance issues • The Australian Experience • What registration really means • Client/Revenue/Arbitrator? European Fiscal Services Ltd ian.hayes@e-fisc.com

17. Tax Practice in the Future – 4 Sandwich filling? • Forensic • Recovery • Restoration • Support through litigation • Untying the knots • Cross border transactions • New Taxes European Fiscal Services Ltd ian.hayes@e-fisc.com

18. Tax Practice in the Future - 5 – Points for discussion • Risks involved • Where does the profit come from • Relations with clients • Relations with revenue • Regulation, Registration or laissez faire European Fiscal Services Ltd ian.hayes@e-fisc.com

19. The future of Tax Practice Thank you! Food for thought? European Fiscal Services Ltd ian.hayes@e-fisc.com