IBFed paper on the Taxation of the Digital Economy

This IBFed paper considers the recent consultation on taxation of the digital economy by the OECD (published in March 2018) and the proposal by the European Commission that same month of a Digital Services Tax. In our paper we explain why banks are inherently different from other businesses as they generally have a regulated / licences presence in the jurisdictions in which it operates and have a different business model as pure digital players. Measures taken must be internationally coordinated in order to avoid the danger of double or multiple taxation. The paper attached will be used in engagement with the European Commission and the OECD. IBFed Paper to the OECD_25… Read More

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IBFED Response to the BCBS consultation on Pillar 3 (3rd phase of the review)

The IBFED supports the aim of transparency that should be accomplished by means of Pillar 3 disclosures requirements. However, we have concerns with the proposed disclosure of certain sensitive or proprietary information in phase three. At the same time, we emphasize that the focus must be on disclosures that are relevant for users. The proposed amount of information to be disclosed increases the risk of misinformation and reduces comparability. This would be counterproductive. Examples to illustrate these concerns are provided below. IBFED Letter_25 May IBFed Pillar 3_final  

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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 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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