In our letter we comment upon the Effects Analysis IASB consultation regarding “IFRS exposure draft amending its Dues Process Handbook“. We believe our response to the IFRS exposure draft could set a benchmark for both IFRS and FASB as to how “Effects Analyses” should address bank-specific concerns. In addition, it includes a discussion related to expanding the IFRS Foundation’s standard due process to their “Agenda Decisions”, which are interpretations of existing standards. While subject to IASB approval, these Agenda Decisions can often change bank accounting practice and, therefore, should be subject to a robust review process. IBFed Comments IFRS Due Process Effects Analysis_25 July 2019
Continue ReadingAddressing the Tax Challenges of the Digitisation of the Economy
We welcome the opportunity to provide input as part of the OECD’s consultation set out in the public consultation document “Addressing the Tax Challenges of the Digitalisation of The Economy – 13 February – 6 March 2019”. Euro In our letters we refer to our paper dated 25 September 2018 setting out some of the concerns of the International Banking Federation (IBFed) in relation to the taxation of global banks, and how banks differ from highly digitalised businesses which featured as the primary focus of the OECD’s interim report in March 2018. We explain further how banks generally have a regulated / licences presence in the jurisdictions in which they operate… Read More
Continue ReadingRevisions to Basel 3 and the treatment of securities financing transactions
IBFed letter to BCBS on capital treatment of SFTs_11jan19 The IBFed appreciates the Basel Committee on Banking Supervision (BCBS) efforts to revise the Basel 3 standards. The International Banking Federation (IBFed) has submitted numerous letters to the BCBS discussing various Basel 3 revisions and making recommendations for practical, and objective-focused ways those standards can be adopted. We anticipate that as domestic jurisdictions begin adopting the latest round of finalized standards, issues that were not previously anticipated or fully appreciated will present themselves. This letter addresses one of these specific issues, the minimum haircut floors for Securities Financing Transactions (SFTs), about which we have not previously commented.
Continue ReadingIBFed 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
Continue ReadingIBFED 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
Continue ReadingIBFED 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
Continue ReadingIBFED Newsletter February 2018
In the February 2018 edition we comment upon the IBFED Board held in Tokyo, the Prudential Supervision WG held in Frankfurt, the Basel Committee workshops on FinTech in New York and Singapore and an overview of the upcoming meetings. IBFED Newsletter February 2018
Continue ReadingTax 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
Continue ReadingIntra-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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