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  • Publications | Tax | PwC Ireland | Services
    of metrics This is enhanced by the strong pipeline of recent Irish investments by new and existing investors across all sectors see pages 2 3 In this issue we highlight that confidence in Ireland s economy and business is at an all time high as illustrated in PwC Ireland s 2015 CEO Pulse Survey Other topics covered in this edition include a snapshot of new Irish GAAP rules regarding FRS 101 102 our proposed Knowledge Development Box and a selection of other FDI events and developments September 2015 Global tax transparency and risk management The new landscape prompts changes to operations strategy and budgets September 2015 Revenue to target the construction sector Revenue announced in a recent publication it s intention to focus on tax compliance in the construction sector with a particular focus on Relevant Contracts Tax RCT This bulletin sets out the key risks for companies operating in the construction sector if subject to a Revenue intervention September 2015 PwC submission document on the tax treatment of expenses for Non Executive Directors attending board meetings In August 2015 PwC responded to the invitation from the Minister for Finance for submissions to be made to the Department of Finance as part of the consultation on the Tax Treatment of Travel and Subsistence for Employees and Office Holders The focus of the submission was on the tax treatment of expenses for Non Executive Directors NEDs attending board meetings August 2015 Taxing times for global business Despite evidence that governments around the world are reducing tax costs and compliance these efforts are not being felt by CEOs Here we explore some of the reasons for the disparity July 2015 International tax news July 2015 This monthly newsletter from PwC s international tax network provides an overview of international tax developments from countries worldwide In this edition new tax legislation and tax treaties are announced for a number of countries around the globe July 2015 Global Research Development Incentives Group June 2015 Investing in Ireland Issue 23 The strong pipeline of Irish investments by new and existing investors across all sectors continues in 2015 with Dublin being recognised as one of the world s most vibrant cities In addition the Harvard Business Review has also recently named Ireland as a standout digital economy and all the leading FDI rankings continue to show Ireland as the number 1 global FDI destination based on a range of metrics This issue provides an overview of Ireland s very important economic relationship with the US which has recently been recognised as the leading international export platform for US groups It also provides a snapshot of some recent developments in the people mobility and reward space June 2015 OECD releases model documents for implementing country by country reporting On 8 June 2015 the OECD released a Country by Country Reporting Implementation Package The package includes model legislation the OECD suggests could be used by countries to mandate filing of country by country reports CbCRs The model legislation does not attempt to address the filing of the so called master file or local file reports The implementation package also includes three model competent authority agreements that could be used by each country depending on how it intends to effect exchange of CbCRs June 2015 European Commission s Joint Transfer Pricing Forum mandate and new composition confirmed On 12 May 2015 the Director General for Taxation and Customs Union appointed the Members and the Chairperson of the EU Joint Transfer Pricing Forum JTPF for the next two year mandate starting on 1 April 2015 till 30 March 2017 For the first time since its set up in 2002 the European Commission has appointed organisations rather than individuals The new composition of the JTPF also includes non governmental institutions alongside multinational enterprises Professional Services Firms industry organisations and government representatives of each Member State June 2015 OECD guidance on transfer pricing aspects of intangibles hard to value intangibles The OECD has published a discussion draft on the arm s length pricing of intangibles when valuation is highly uncertain at the time of the transaction or the intangibles are hard to value The discussion draft released 4 June 2015 is part of Action Item 8 of the OECD s Base Erosion and Profit Shifting BEPS Action Plan Action Item 8 is focused on assuring that transfer pricing outcomes with respect to intangibles are in line with value creation June 2015 International tax news June 2015 This monthly newsletter from PwC s International Tax Network provides an overview of international tax developments from countries worldwide In this edition new tax legislation and tax treaties are announced for a number of countries around the globe June 2015 PwC India Indirect Tax Customs newsletter May 2015 This newsletter provides important judicial and legislative developments relating to service tax central excise VAT CST customs foreign trade policy WTO provisions in India May 2015 Transfer pricing announcements in Australian Federal Budget The Australian Government s 2015 16 Federal Budget released on 12 May contained several measures targeted at multinationals The key announcements included A commitment to implement the new OECD transfer pricing documentation requirements including country by country CbC reporting from 1 January 2016 Higher penalties for companies that enter into tax avoidance or profit shifting schemes A new anti avoidance rule aimed at multinationals selling to Australian customers where the revenue and profits are booked by a non resident under a structure that is designed to avoid creating a permanent establishment PE in Australia Other relevant announcements included the provision of additional funding to the Australian Taxation Office ATO for auditing transfer pricing and international tax issues under its International Structuring and Profit Shifting Project and taking steps towards adopting other actions from the OECD Base Erosion and Profit Shifting project such as anti hybrid rules May 2015 OECD releases revised base erosion and profit shifting proposals on permanent establishments The OECD has released its revised proposals on the Permanent Establishment PE rules in Article 5 of the OECD Model Tax Treaty The earlier OECD proposals which set out alternative approaches to a number of significant PE issues have been replaced by a set of definitive proposals which are largely focused on expanding the scope of the dependent agent rule including narrowing the scope of the independent agent rule and narrowing the scope of the specific activity PE exemptions An important element of the package is a proposed anti fragmentation rule intended to prevent abuse of the PE rules by segregating activities across associated entities Taken together the proposed rules will clearly expand the scope of existing PE rules May 2015 International tax news May 2015 This monthly newsletter from PwC s International Tax Network provides an overview of international tax developments from countries worldwide In this edition new tax legislation and tax treaties are announced for a number of countries around the globe May 2015 Base erosion and profit shifting BEPS proposals address intangibles cost contribution arrangements Multinational enterprises involved in the development and use of intangibles under cost contribution arrangements CCAs should note the 29 April 2015 discussion draft proposals under Action 8 of the Base Erosion and Profit Shifting BEPS Action Plan The discussion draft proposes fundamental modifications to Chapter VIII of the OECD Transfer Pricing Guidelines May 2015 International tax news April 2015 This monthly newsletter from PwC s International Tax Network provides an overview of international tax developments from countries worldwide In this edition new tax legislation and tax treaties are announced for a number of countries around the globe April 2015 European investor tax reporting Investor tax reporting is a complex and constantly evolving area In recent years several jurisdictions including Austria Germany Switzerland and the UK have introduced new tax reporting regimes or modified existing ones In order to compete and effectively market their products across Europe fund managers now require a deeper understanding of country specific investor tax reporting requirements The dedicated asset management tax team in PwC Ireland presents a comprehensive multi jurisdictional tax reporting solution for investment funds March 2015 Investing in Ireland Issue 22 The strong pipeline of new Irish investments by first time and existing investors continues in 2015 with Dublin being recognised as one of the world s most vibrant cities On the legislative front the entry into law in June 2015 of Ireland s Companies Act 2014 as well as planning for the Knowledge Development Box to be introduced in 2016 will be of interest to new and existing investors alike For companies in the online B2C sector the new 2015 VAT rules should mean that Ireland is an even more attractive location for such businesses to locate centralised EU hubs which can manage all EU VAT obligations March 2015 PwC India Indirect Tax Customs Newsletter February 2015 This newsletter provides important judicial and legislative developments relating to Service Tax Central Excise VAT CST Customs Foreign Trade Policy WTO provisions in India February 2015 European cities hotel forecast for 2015 and 2016 Room for growth The survey benchmarks occupancy and average daily room rates and growth for 20 gateway European cities including Dublin for 2015 and 2016 It finds that Dublin has the highest revenue per room for 2015 and 2016 March 2015 Tax facts 2015 This publication is a practical and easy tofollow guide to the Irish tax system It provides a summary of Irish tax rates as well as an outline of the main areas of Irish taxation February 2015 U K patent box claims As part of the Government s aim to encourage innovation in the UK and increase tax competitiveness a 10 tax rate now applies to profits falling within the Patent Box This provides a significant tax saving compared to the main rate of corporation tax in the UK February 2015 Multinationals receive OECD country by country reporting multilateral instrument and IP tax incentive BEPS proposals Multinational enterprises MNEs recently received additional guidance on complying with certain recommendations emanating from the OECD s base erosion and profits shifting BEPS Action Plan MNEs will be particularly interested in the roll out of country by country tax information reporting to tax authorities They will also be interested in the criteria countries should require in order for them to benefit from intellectual property IP tax incentive regimes February 2015 Italy s new Patent Box regime additional flexibility Italy has introduced a Patent Box regime based on the nexus approach set out by the Organisation for Economic Co operation and Development OECD Only a month after the Italian Parliament approved the 2015 Finance Act Law no 190 of December 23 2014 which enacted the Italian Patent Box regime the Italian Government has extended its scope through a Law Decree Investment Compact which is due to be converted into law within 60 days of its publication in the Official Gazette on January 24 2015 February 2015 Customs International Trade Communiqué edition 67 In this edition you will find articles regarding ECJ case law changes in EU legislation some country specific updates including recent excise changes in Ireland and the usual updates on tariff classification and anti dumping February 2015 PwC India Indirect Tax Customs Newsletter January 2015 This newsletter provides important judicial and legislative developments relating to Service Tax Central Excise VAT CST Customs Foreign Trade Policy WTO provisions in India February 2015 International tax news February 2015 This monthly newsletter from PwC s International Tax Network provides an overview of international tax developments from countries worldwide In this edition new tax legislation and tax treaties are announced for a number of countries around the globe February 2015 RCT obligations for the Telecommunications Sector Overview of RCT considerations for those operating in the Telecommunications Sector January 2015 International tax news December 2014 January 2015 This monthly newsletter from PwC s International Tax Network provides an overview of international tax developments from countries worldwide In this edition new tax legislation and tax treaties are announced for a number of countries around the globe January 2015 Knowledge development box Consultation process On October 14 2014 the Minister for Finance delivered the Irish Budget for 2015 in which he announced plans to introduce a new Knowledge Development Box KDB The Department of Finance launched a public consultation on the KDB regime on January 14 2015 They have requested submissions to be made on the design of the KDB with the goal of ensuring it meets its key objective of being the most competitive in class within the agreed international parameters for fair tax competition in this area The consultation process runs until April 8 2015 January 2015 UK to introduce legislation to implement country by country reporting Following the UK s lead as the first country to commit publicly to adopting the country by country reporting CBCR template developed by the Organisation for Economic Co operation and Development OECD the Government has now published the draft legislation to enable the introduction of CBCR in the UK The legislation which will be included in the Finance Act 2015 confirms that UK parented multinational enterprises MNEs will be required to provide CBCR tax related data to HM Revenue Customs HMRC as part of this requirement The draft legislation and its accompanying explanatory notes also indicates how the implementing regulation is to be introduced as well as the impact it is expected to have on business The draft legislation at this point does not specify a proposed date for implementation but the expectation is that MNEs will be required to prepare the CBCR template for financial years beginning on or after 1 January 2016 January 2015 Australia Transfer pricing documentation simplification measures The Australian Taxation Office ATO has published its online guidance in relation to Simplifying transfer pricing record keeping If a taxpayer elects to apply a simplified record keeping option outlined in this guidance Practice Statement Law Administration PS LA 2014 3 explains that the Commissioner will not review the taxpayer s records beyond confirming its eligibility This guidance provides effective safe harbours for small taxpayers small to medium sized distributors low risk intragroup services and low level intragroup loans January 2015 Emerging trends in real estate 2015 Emerging Trends in Real Estate Europe a trends and forecast publication now in its 12th edition is a highly regarded and widely read report in the real estate industry Undertaken jointly by PwC and Urban Land Institute the report provides an outlook on real estate investment and development trends real estate finance and capital markets cities property sectors and other real estate issues throughout Europe Emerging Trends in Real Estate Europe 2015 reflects the views of nearly 500 individuals who completed surveys or were interviewed as a part of the research for this report The views expressed including all comments appearing in quotes are from these surveys and interviews and do not express the opinions of either PwC or ULI The interviewees and survey participants represent a wide range of industry experts including investors fund managers developers property companies lenders brokers advisers and consultants January 2015 Discussion drafts released in six BEPS related areas raise more concerns for MNEs Multinational enterprises MNEs may be concerned about various aspects of the six Discussion Drafts released last week as part of the Base Erosion and Profit Shifting BEPS Action Plan Three of the papers are within Action items 8 to 10 of the BEPS Action Plan dealing with assuring that transfer pricing outcomes are in line with value creation One of the other papers is the first step towards producing best practice rules to address base erosion and profit shifting through the use of interest expense within Action item 4 of the Plan The latest proposed additions to the draft International VAT GST Guidelines relate to supplies of services and intangibles to consumers raised in the initial report on the digital economy within Action 1 The final paper is an overarching look at the resolution process involving cross border tax disputes Responding directly to the OECD with specific examples is the most powerful way that businesses can address issues which would arise if proposals were adopted Businesses may also like to consider attending and speaking at the various public consultation meetings on these papers at the OECD s offices in Paris January 2015 Australia Final ATO guidance on transfer pricing documentation and penalties The Australian Taxation Office ATO has finalised its guidance on transfer pricing documentation and penalties under the new transfer pricing regime The final guidance was issued in Taxation Ruling 2014 8 on transfer pricing documentation and two practice statements PS LA 2014 2 on penalties under the new transfer pricing regime and PS LA 2014 3 on simplifying transfer pricing record keeping The simplification guidance will provide exemptions from preparing transfer pricing documentation for certain categories of taxpayers and transactions The details and eligibility criteria will be published in an online guide which is expected to be available within the next week PwC will issue a further update when the guide is published January 2015 UK Diverted Profits Tax to be introduced HM Revenue Customs HMRC released the diverted profits tax DPT provisions within its draft Finance Bill 2015 From our initial review of the legislation many more companies than might have been anticipated could be effected by these new rules The DPT is a new tax charged at 25 on profits that are considered to be artificially diverted from the UK The legislation is very complex there are two sets of conditions where DPT would be applicable and often both will apply to the same fact pattern In summary the DPT might apply to a company which has UK sales being made by a related non UK company or Permanent Establishment PE and or a UK company PE which has a significant transaction with a related company and in either case any related income ends up in a related company with a low tax rate concessionary tax treatment January 2015 PwC India Indirect Tax Customs newsletter

    Original URL path: http://www.pwc.ie/services/tax/publications.html (2016-02-18)
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  • How can we help? | Asset management | PwC Ireland | Industries
    domiciled funds 13 000 We have over 13 000 asset management professionals across 157 countries The funds industry is a continually changing landscape We have the knowledge and experience to assist you with your audit tax and advisory needs across all the main types of funds including hedge funds private equity UCITS ETFs money market funds real estate property funds Islamic funds and more Using our specialist asset management group the largest in Ireland and our extensive global network we can tailor our approach to suit your particular fund type and provide market insights and experience that are second to none Setting up a fund We can help with all aspects of setting up a fund This includes developing your market entry strategy regulatory accounting tax and operational advice on initial fund setup and project managing the fund setup process Fund audit Trust is an important factor in gaining and sustaining the confidence of your investors Using our experience and proven track record we can provide the stamp of approval needed to give comfort to you and your investors Fund tax We have a dedicated group of tax professionals focused on international and local tax issues facing fund managers We have a wealth of resources and expertise to assist you in addressing the various tax challenges such as Investor tax reporting Withholding taxes review Financial transactions taxes Transfer pricing FATCA International tax consulting services EU witholding tax reclaims Global tax compliance services VAT services Regulatory assistance Keeping up to date with the regulatory environment is essential We can provide you with clear guidance on what you need to do to be compliant and help you to identify the impact of these regulations on your business your processes and your people Asset management consulting The asset management sector is constantly changing

    Original URL path: http://www.pwc.ie/industries/asset-management/how-can-we-help.html (2016-02-18)
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  • Hedge funds | Asset management | PwC Ireland | Industries
    Spain Sweden Switzerland United Kingdom United States Complete list of PwC territory sites Hedge funds Ireland is recognised worldwide as a leading domicile in the hedge fund industry and here s why 40 of the global hedge funds are serviced in Ireland making it the largest hedge fund administration centre in the world 50 of the top 10 European hedge fund managers have set up hedge funds in Ireland 235bn is the total amount of Irish domiciled hedge fund assets So what makes Ireland the location of choice for your hedge fund Ireland is AIFMD ready It has a world class tax environment 12 5 corporation tax no net asset tax no fund tax Ireland has the right expertise servicing over 1 trillion of alternative fund assets It has the right Alternative Investment Fund AIF structures for hedge funds It allows for non EU managers to appoint self managed AIF as the AIFM Ireland has removed the promoter approval regime for hedge funds and other AIFs It already requires the appointment of an independent depositary as now required under AIFMD Ireland allows hedge funds seeking to move onshore to a regulated fund jurisdiction a streamlined fund re domiciling process Ireland is an English speaking common law jurisdiction with a high quality business friendly environment and a highly developed support infrastructure How can we help Hedge funds are a specialist product We have a team of experts with extensive experience of hedge funds who offer services tailored to the needs of hedge fund managers their funds and their service providers In fact 80 of the top global Hedge Fund Intelligence listed hedge funds and 100 of the top 10 European hedge fund managers are serviced by PwC Asset management Hedge funds Exchange Traded Funds UCITS Your fund distribution strategy Setting up

    Original URL path: http://www.pwc.ie/industries/asset-management/am-hedge-funds.html (2016-02-18)
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  • Exchange Traded Funds | Asset management | PwC Ireland | Industries
    Funds ETFs ETFs domiciled in Ireland manage assets in excess of 140 billion This represents over 30 of the European market So what makes Ireland the location of choice for your ETF Experience expertise Investment managers can benefit from working with Irish service providers and a Regulator who knows the ETF product Irish fund administrators have strong expertise and customised systems for servicing ETFs Tried tested More than 850 fund promoters from over 50 countries have chosen Ireland including some of the largest ETF providers in the world Mature industry ETFs were first launched in Ireland back in 1998 therefore Ireland has years of experience in establishing and servicing ETFs Attractive tax environment There is no annual net asset tax for ETFs and where Ireland has a double taxation treaty in place ETFs may be entitled to lower withholding tax rates How can we help 70 We work with in excess of 70 of the leading ETF players in Ireland structuring both physical and synthetic ETFs 91 We audit 91 of the ETFs located in Ireland We can offer you a tailored approach to your business issues covering everything from Setting up your ETF Delivering an efficient audit Designing and

    Original URL path: http://www.pwc.ie/industries/asset-management/exchange-traded-funds.html (2016-02-18)
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  • UCITS | Asset management | PwC Ireland | Industries
    in Ireland 3 000 the number of Irish UCITS funds approved for cross border distribution 70 the number of countries where Irish UCITS are distributed Why Ireland Ireland is renowned as a centre of excellence for UCITS products with 80 of Irish domiciled funds falling under the UCITS regime It is the fastest growing major cross border UCITS domicile globally and is the leading jurisdiction in Europe for two of the main types of UCITS ETFs and Money Market Funds Some of the largest global asset managers have UCITS in Ireland Distribution is paramount to the success of the UCITS product Irish domiciled funds are distributed to a large number of countries across Europe the Americas Asia and the Pacific the Middle East and Africa We can help with everything from setting up your UCITS the fund audit tax reporting and more For more information view our How can we help page As the next iterations of the UCITS Directive namely UCITS V VI are under consultation we can share our market insights on the proposed changes We can provide clear guidence on what you need to do to be compliant with the proposed new rules Asset management Hedge funds

    Original URL path: http://www.pwc.ie/industries/asset-management/ucits-funds.html (2016-02-18)
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  • Your fund distribution strategy | Asset management | PwC Ireland | Industries
    States Complete list of PwC territory sites Your fund distribution strategy What s new Global fund distribution services Private placement or passporting Global hedge fund distribution survey 2015 Distribution disrupted Spotlight on alternatives Fund distribution in Switzerland Fund distribution in Europe 2015 Introduction to Ireland s fund distribution services Market entry and cost analysis review Pre analysis of the requirements and costs linked to initial and post registration activities needed for the countries into which the fund will be marketed Fund registration All steps of the initial registration for your fund sub funds ensuring complete transparency for filings Maintenance All post registration tasks to maintain your fund s authorisation for public distribution in host countries Tax reporting Ensuring your funds are tax compliant in all distributing jurisdictions Managing a fund distribution strategy is time consuming especially with the introduction of AIFMD Rules differ in each country particularly for non EU managers utilising the National Private Placement Regimes NPPRs While the UCITS rules are generally streamlined there are number of country variations You need to be aware of complex regulatory constraints tax reporting rules and a myriad of local market requirements Our team understand these challenges and can help you with

    Original URL path: http://www.pwc.ie/industries/asset-management/your-fund-distribution-strategy.html (2016-02-18)
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  • Setting up a fund in Ireland | Asset management | PwC Ireland | Industries
    a fund in Ireland We understand your business and the challenges of setting up a new fund in a new jurisdiction Outlined below is some guidance on how to set up a fund in Ireland How do I set up a fund in Ireland To set up a fund in Ireland you must obtain authorisation from the Central Bank of Ireland There are a number of steps involved Choose a fund structure There are two main fund regimes in Ireland UCITS and AIFs There are a number of factors to consider when making this decision including the location of target investors and the investment policy of the fund Choose a legal structure The following legal structures are available in Ireland Investment Company Unit Trust Common Contractual Fund CCF and Investment Limited Partnership Required service providers The Central Bank of Ireland CBI is the authority responsible for the authorisation of funds in Ireland They will approve all the below mentioned service providers For all Irish funds a number of service providers must be approved in advance including An Irish based depository An Irish regulated external auditor An Irish based administrator central administration A management company Unit Trust and CCF and Two Irish resident directors In the case of a UCITS the fund promoter and the investment manager only if different to the promoter must also be approved by the CBI For AIFs the investment manager must obtain approval as an AIFM from the CBI Fund approval Once the promoter investment manager have been approved the final step is obtaining approval for the fund documentation How can we help We can provide assistance with the market entry strategy for your fund and provide assistance with the set up and establishment of your fund through regulatory accounting tax and operational advice For more

    Original URL path: http://www.pwc.ie/industries/asset-management/setting-up-a-fund-in-ireland.html (2016-02-18)
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  • Independent director network | Asset management | PwC Ireland | Industries
    Real estate Retail and consumer Services for legal firms Technology Media centre Articles Press releases Publications RSS feeds Careers Experienced careers Student careers Executive search Ireland International PwC Sites Commonly visited PwC sites Global Australia Brazil Canada China Hong Kong France Germany India Italy Japan Mexico Middle East Netherlands Russia Singapore South Africa South Korea Spain Sweden Switzerland United Kingdom United States Complete list of PwC territory sites About the network The aim of this network is to provide a forum for you as independent directors of funds and fund management companies to discuss common challenges with your peers Read more In the spotlight Supporting your business journey Findings from our most recent remuneration survey of Ireland s Fund Directors Click here to download the full report Events Save the date for our upcoming Governance briefing on Wednesday 11 November 2015 Find out more Find out more A risk management framework is vital in today s business environment A risk management framework comprises many different components Tone at the top is important when implementing a risk management framework View archives Asset management Hedge funds Exchange Traded Funds UCITS Your fund distribution strategy Setting up a fund in Ireland Fund domicile

    Original URL path: http://www.pwc.ie/industries/asset-management/irish-fund-independent-director-network.html (2016-02-18)
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