FL860 – Tax Transparency

The objective of this course is to analyze international tax transparency under the current standards-driven by OECD and EU law. Tax transparency requires public and private institutions (financial institutions, trustees, tax advisors) to disclose tax-related information, exchanged between tax administrations. Different methods are made available for this purpose: notably the automatic, upon request and spontaneous exchange of information. Adding, tax administrations have other techniques at their disposal, to conduct simultaneous examinations, offshore tax exams, and in more delicate cases, exchange industry-wide information. The personal scope of the legislation expands, to cover both individuals and corporations. The provisions provide for the exchange of bank account information, named types of revenues, tax rulings, advance pricing arrangements, and planning. The exchanged information relates to past and forecast future events- foreseeably affecting the taxpayer’ s position. The provisions are triggered as regards tax liability in different states or if issues under anti-money laundering audits arise. EU external strategy for Effective taxation propulses the standard to third countries, crucially increasing the compliance costs borne by corporations. The approach suggested delivers a systematic and comprehensive tool to domestic implantation rules, enacted by Tax and Regulatory authorities. By the end of the course, students are expected to master compliance standards driven by tax transparency rules, detect legal risks related to international standards circumventions (beneficial ownership and anti-money laundering), and proactively fashion their tax strategy in a consistent way, on a case by case basis.