Financial Services Tax in Tax and Legal blog
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How tax authorities use the data received under the Automatic Exchange of Information (AEOI) – An Italian example
Tax authorities around the globe are making use of the financial account information they receive through the AEOI regime based on the OECD Common Reporting Standard (CRS); Italy is no exception. The Italian Tax Authorities (ITA) are using the gigabytes of AEOI data collected to confront certain taxpayers who have presumably omitted and/or only partially fulfilled their tax settlement and reporting obligations. Consequently, the ITA are issuing letters of compliance to certain taxpayers with respect to financial assets held abroad in 2017 (and any related income), which encourage them to take voluntary remediation action to meet their obligations. Notably these letters now specifically refer to assets held in Switzerland. The letters aim at highlighting discrepancies between the data taxpayers have filed in their tax return and the data the ITA received through the AEOI mechanism. Such discrepancies do not necessarily reflect taxpayer mistakes as there may well be differences between the AEOI data and the information captured on tax returns. That being said, recipients of compliance letters are strongly recommended to proactively engage with the ITA to clarify their situation, which may mitigate the risk of further inquiries.
The ever-evolving role of an Automatic Exchange of Information (AEOI) responsible person - Join our live training on 3 March at 16.00 CET
Both US FATCA and the OECD’s Common Reporting Standard (CRS) require Financial Institutions (FIs) to put in place processes, procedures and overall governance to enable accurate reporting of information about the FI’s account holders and/or controlling persons thereof, to certain tax authorities. These rules, which are commonly referred to as the Automatic Exchange of Information (AEOI), have become business as usual over the past six years. However, these rules are practically complex to implement and maintain, and can expose FIs to significant risks. Key challenges include manual processes, local expertise requirements, systems interfacing, documentation and data deficiencies, and requirements that are often unclear and continuously change. Jurisdictions around the globe are starting to take audit action.
The OECD recently released two documents evidencing its perseverance in ensuring an effective implementation of and a level playing field with regard to its Common Reporting Standard (CRS) for the automatic exchange of financial account information:
Deloitte’s 2020 global survey on the OECD’s Base Erosion and Profit Shifting (BEPS) initiative shines a spotlight on the next wave of the Global Tax Reset. What are the key finding and impacts on the financial services industry?
Under Australian domestic law, eligible foreign pension funds deriving Australian source interest and dividend income are eligible for Australian withholding tax exemptions. The Australian government introduced new laws in early 2019 to amend the rules in respect of Australian withholding tax exemptions for foreign pension funds.
The initial reporting of certain cross border arrangements under DAC6 was scheduled for the end of July 2020. Shortly before the DAC6 go-live date, the EU agreed on an optional six-month extension. Approximately one week after the EU agreement, some countries have communicated their position, others are silent, and at least one is not intending to provide an extension. We are here to help you keep an overview of the individual countries’ positions.