S18 & EUSD

Background to EUSD

 Cross border tax evasion in the EU  Threat of EU-wide WHT  Exchange of information  Some countries impose WHT  Knee-jerk reaction  What consultation?

Two sets of rules in one report

 Rules are confusing – (especially if you deal with QI as well)  Unit Trusts/Collectives  PEPs/ISAs/CTFs  Joint accounts  Trusts  What harmonisation could be done?

DOCUMENTATION - EUSD

 The language problem  Which number is the TIN?

 Reluctance for sending originals  Problems of certification  Why use the term TIN?

 Client confusion  Confusion for people in non-EU countries

What do the local tax authorities do with the information?

 TIN  Place & date of birth  Costs & Benefits

Audit experience

 S18 audit for 2004/5  Penalties

Tax collected in 6 Months

 Switzerland £69m  Jersey £9m  Guernsey £3m Where has all the taxable income gone?

What now?

 “The Europeans love it and want to extend the EUSD to equities”  The EU are reviewing the scope of the EUSD  Post implementation review  Revenue simplification  APCIMS initiative

IS ANYONE AWARE OF:

 The mandatory requirement for Authorised Investment Funds to pay Distributions Gross to so-called No-Net Liability Taxpayers?