IBFED Response to the draft FATF paper on « Vulnerabilities linked to the concealment of beneficial ownership »

In our response we acknowledge the importance of the FATF document as it contains numerous case studies whereby specific structures are abused to conceal the beneficial owners. We further point out that there is a widening gap between the obligations applicable to financial intermediaries and those applicable to other professions. Hence we want to avoid new requirements and recommendations for financial intermediaries. And we also mention that digital solutions supported by government agencies or official authorities are probably more efficient. IBFED Response to FATF_5 April 2018_Beneficial Ownership  

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Tax Policy Design for Banks

Document on Tax Policy Design for Banks that can be used by IBFED members for in country discussions, as appropriate. The document reflects the view on appropriate tax policy design for global banks, commenting upon the OECD Tax Policy Principles applicable for banks. We argue that tax policy should not discriminate between taxpayers, or industry groups (eg bank levies or surcharges and that banks should not automatically be seen a collection mechanisms). It will be shared with the OECD during our upcoming meetings in March 2018. Tax Policy and Design for Banks_30 January 2018

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Intra-group Funding by Global Banks

Paper on pricing related party debt for banks that will be shared with the OECD in March 2018. We discuss the issue of intra-group lending which can be significant for global banks. They must adhere to arm’s length principles when conducting such intra-group lending. We argue that there needs to be flexibility to determine the arm’s length price. The Revenue Authorities should accept a number of different alternative approaches, including using external issuances or pricing from an internal mechanism (such as a yield curve). IntraGroup lending_30 January 2018

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Response to the OECD on the tax challenges of the digitised economy

Like the OECD we are committed to a global tax system which avoids both double non-taxation and double or multiple taxation. We acknowledge the comments made by the OECD that banking activities are not the target of potential taxes aimed at the provision of digital products and services across borders. We note that consideration is being given to equalisation and withholding taxes. We advocate that banks should not be required to act as withholding agents in relation to any withholding taxes. IBFED Response to OECD_27 November 2017  

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IBFED Response to the BCBS Consultation on Fintech

The IBFed appreciates the opportunity to provide comments on the Consultative Document. At this time, we support each jurisdiction’s own bank supervisory agencies in their efforts to address the challenges and opportunities related to emerging fintech technologies while continuing to encourage comparably equivalent national regulatory approaches. Bank supervisors have the authority to supervise banks. Developing an international fintech regulatory framework may have its merits in certain circumstances, as is demonstrated by FATF for example, but could be premature regarding the fast-changing digital environment and because most bank supervisors don’t have the authority to provide this oversight within their own jurisdiction let alone across borders. IBFED Response to BCBS on, 31 Oct… Read More

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IBFed Response to IOSCO on Secondary Corporate Bond Markets

The IBFed appreciates the opportunity to provide comments to the IOSCO consultation report entitled, Regulatory Reporting and Public Transparency in the Secondary Corporate Bond Markets (Report).  The Report states that IOSCO undertook this report as part of its mandate to examine the global corporate bond markets, specifically focusing on issues related to regulatory reporting, transparency, and the collection and comparison of data across national jurisdictions. Response to IOSCO Secondary Corporate Bond Markets, 16 Oct 2017

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