True Partners Consulting (UK) LLP is holding a 40 min webinar on European and UK VAT on 24th February at 4:30pm UK GMT (US-10:30am CST).
Our experts will cover the following areas:
• Overview of main forms of indirect tax
• Key concepts and issues
• Outline of the UK VAT system
• European Developments
• VAT and Transfer pricing interaction – Intercompany charges
• Case studies
Who is this webinar most appropriate for?
• All UK companies and partnerships with employees including ‘Not for Profit’ sector; and
• Any overseas company with operations in the UK and Europe
Target Audience: CFO’s, Finance Directors, Financial Controllers, VAT teams, International Tax teams, EMEA Tax controllers.
Key client issues:
• Need to comply with ever increasing compliance obligations
• Need to maximise VAT recoveries
• Need to reduce negative impact of VAT on cashflow
• Aim to minimise HMRC Risk rating and reduce risk of penalties
• Desire to simplify administration
Questions for audience to consider as part of the webinar:
• Are you confident that you are accounting for the right VAT at the right time?
• Are you recovering all VAT which you are entitled to reclaim?
• What steps have you taken to train staff to ensure compliance and awareness of major issues?
• How VAT-efficient is your current arrangements?
• When did you last review your current policies and procedures?
Presenters from UK and Germany.
To Register: contact Abbas Sadak
Abbas Sadak
Director – UK and European Tax
True Partners Consulting (UK) LLP
P 0207 868 2434 • F 0207 868 1800 • M 07957 303 892
Abbas.Sadak@TPCtax.co.uk
True Partners Consulting (UK) LLP will be holding a 40 min webinar on Tuesday 21st February 2012 at 3:00pm UK GMT (US – 9:00am CST).
The purpose of the webinar is to provide an overview and guidance to UK and European Financial Controllers, Finance Directors, In-house tax managers etc on a structured approach for the identification of transfer pricing risk as part of the audit of tax provisions (i.e. statutory accounts preparation and reporting of tax numbers).
The presentation will also focus on risk assessments for trading transactions.
Our presentation will involve specialists from our European affiliates.
Who is this webinar most appropriate for?
• All UK companies and partnerships with employees including ‘Not for Profit’ sector; and
• Any overseas company with operations in the UK and Europe
To register, please contact Abbas Sadak (contact details listed below). Dial in details for the webinar will be provided nearer the time.
Abbas Sadak
Director – UK and European Tax
True Partners Consulting (UK) LLP
P 0207 868 2434 • F 0207 868 1800 • M 07957 303 892
Abbas.Sadak@TPCtax.co.uk
TPC UK has prepared a paper which is designed to provide an insight into the main types of share plans available in the UK and practical guidance for international companies wishing to extend their existing plans to UK-based employees. Many internationally-based companies have major operations in the UK, but few consistently extend their share incentive plans to include UK employees, due to misconceptions over the associated cost and complexity.
If you would like a copy of the white paper or would like to discuss any share planning ideas, please contact Les Secular or Abbas Sadak.
Online filing changes for corporation tax are due to be effective from April 2011. A significant impact of this change is the requirement for companies to file their returns and accompanying documentation in Extensible Business Reporting Language (“XBRL”).
We are currently assisting finance and tax departments in managing iXBRL. with tagging statutory accounts as well tax computations such that these are filed in the required formats as required by HMRC and Companies House.
Our accounting software incorporates the following features:
• Convert statutory accounts documents (Word) into an iXBRL format
• Automatically tags most of the statutory account numbers
• Compliant with UK GAAP and IFRS accounting standards & taxonomies
• User may adopt manual tagging or override automatically assigned tags
• Intelligent data dictionary memory tagging
Our tax software also includes a fully automated tagging process into Alpha tax.
Feel free to contact Abbas Sadak at True Partners Consulting (UK) LLP incase you would like to have a demonstration of the accounting software or would like to outsource your UK entities accounts or tax computations for converting into the IXBRL. format.
Many multinational corporations face increased fiduciary and legal challenges in order to comply with specific transfer pricing requirements of multiple European tax jurisdictions.
Based on our experience, a number of European countries are implementing much stricter transfer pricing documentation requirements as well as imposing penalties where no support exists.
To prevent US groups with European Subsidiaries having to take a country-by-country transfer documentation approach with all its inherent downsides the European Council approved the Transfer Pricing Documentation Code of Conduct and encourages member states to implement the EU Transfer Pricing Documentation (EU TPD) approach, allowing taxpayers to avoid transfer pricing penalties if they maintain a ‘master file’ of standardised information; and ‘country-specific’ versions of standardised documentation for each member state in which the taxpayer has related party transactions, including documents relevant for that country only. In line with these developments, this provides an opportunity to streamline this process for your European operations.
We have assisted a number of our US clients prepare such documentation in Europe and have also been involved in defending such transfer pricing policies with the relevant European Tax Authorities.
Please ontact Les Secular our European Transfer Pricing Partner based in our London office to discuss your requirements further. Les has over 30 years experience assisting multinational companies with transfer pricing matters.
Do you have subsidiaries in Europe? If so, why not make use of our tax filing tracking tool which enables groups to monitor filing deadlines in a number of European tax jurisdictions. It is expected that this will enable companies to streamline their compliance processes and tax reporting deadlines as well as quantify any tax exposures.
Contact Abbas Sadak for more information.
Multinational Companies (MNC’s) face increasing pressure from various tax authorities to ensure they pay their correct taxes, particularly now when governments attempt to fill their tax coffers whilst businesses face commercial pressures and incur significant losses. By Les Secular, Partner True Partners Consulting (UK) LLP
Employment Taxes
Payroll costs are one of the largest overheads and reducing these costs can generate substantial savings. Most of these ideas involve using “salary sacrifice” so that employees receive additional benefits and/or increased net pay at a lower cost to the employer and are most appropriate if, for example, a full inflationary pay increase cannot be awarded, or you are conducting a review of employee benefits or pension arrangements.
Background
One of the main features of the VAT regime in the European Union (EU) is the VAT invoice, as this is the main tax document that determines when VAT has to be accounted for. It is also the primary document for a business to determine when it is entitled to recover what it has been charged. Historically, the invoices have been in paper form and the rules governing their content and issue have reflected this. However, increasingly businesses have been adopting electronic invoicing and although the VAT Directive provided for electronic invoicing the rules were more restrictive and not consistent across the Member States. In order to address this issue the Council of the EU has adopted a Directive aimed at simplifying the VAT invoicing requirements in particular as regards electronic invoicing.
Summary of the UK Budget delivered by the chancellor on 22nd June 2010
TRUE PARTNERS CONSULTING INTERNATIONAL NETWORK (TPCI) CORDIALLY INVITES YOU to an International Tax seminar to be held in Munich, Germany on June 17th and June 18th, 2010. This seminar will focus on the challenges of managing your tax exposure and risk in an ever changing global marketplace. The topics will be presented both in panel discussions and comprehensive case studies.
Background
The recovery of VAT on deal costs has for many years been a source of dispute between taxpayers and HM Revenue & Customs. This has led to much litigation over the years, with the last few months seeing two high profile cases, both of which resulted in victory for the taxpayer. Although HM Revenue & Customs has already launched an appeal in the first case, and are likely to do so in the second, taxpayers and their advisors should be considering the implications both for deals done in the past and those currently underway.
Viability Studies
The first case that was dealt with in 2009 by the Tribunal, concerned the recovery of VAT on a viability study commissioned to provide information to a prospective lender. The case was taken by My Travel Group (now Airtours Transport Limited), who had been having financial difficulties and needed to restructure their borrowings. Under a tripartite arrangement with a bank and a third party advisor, a viability study was prepared with the advisor invoicing My Travel for the work rather than the bank. My Travel successfully argued that under the principles established by the much earlier Redrow case, it paid for the viability service to be supplied to it and the bank.
As the primary purpose of commissioning the study was to ensure that My Travel could continue to trade and make taxable supplies, it was entitled to recover the VAT in full. HM Revenue & Customs had argued that the supply was made to the bank, with the benefit to My Travel being ancillary. HM Revenue & Customs has appealed against this decision.
Fees incurred by Acquisition vehicle.
The second case concerned the acquisition by Spanish infrastructure group, Ferrovial, of the UK airport operator BAA Plc. As is the case with most large acquisitions Ferrovial set up a new vehicle, NEWCO, to make the acquisition, and NEWCO incurred numerous fees from advisors on which it incurred VAT. Once the acquisition was completed, NEWCO joined the BAA VAT group, though there was a two month gap between the completion of the acquisition and NEWCO becoming a member of the VAT Group.
HM Revenue & Customs argued that the VAT incurred on advisers fees (by NEWCO), was a direct cost of the finance it raised and did not relate to any taxable supplies made by the BAA VAT group.
The Tribunal, however, accepted the argument that NEWCO, as the holding company for BAA, always intended to provide management, strategic advice, corporate governance and financing services to BAA. It was, therefore, carrying on an economic activity from its inception, despite the fact it did not make any charges to its subsidiaries before becoming a member of the VAT group. The Tribunal also concluded that as NEWCO was a member of the BAA VAT group they were a single entity for VAT purposes and the taxable supplies of BAA could be imputed to NEWCO.
Way Forward
The two decisions of the Tribunal provide guidance on a number of technical issues which taxpayers need to be aware of when considering the recovery of VAT on deal costs. Consideration should now be given to the recovery of VAT incurred in the past and the structure of deals in the future, whilst continuing to monitor the further litigation there will be in respect of these cases.