KPMG International Limited

KPMG LLP Tel +44 (0) 20 7311 1000 Tax Fax +44 (0) 20 7311 6452 15 Canada Square London E14 5GL United Kingdom KPMG LLP, a UK limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. Registered in England No OC301540 Registered office: 15 Canada Square, London, E14 5GL For full details of our professional regulation please refer to ‘Regulatory Information’ under ‘About/About KPMG’ at www.kpmg.com/uk Document Classification - KPMG Confidential Directorate-General for Taxation and Customs Union. European Commission 1049 Bruxelles/Brussel.

- KPMG Confidential Directorate-General for Taxation and Customs Union. European Commission 1049 Bruxelles/Brussel. Belgium 1 March 2019 Your ref Our ref Dear Sirs and Madams KPMG Final Remarks to the European Commission’s Public Consultation on the functioning of the administrative cooperation in the field of direct taxation Introduction The European Commission has put out a consultation on the working of the Directive on Administrative Cooperation. The consultation is a multiple choice questionnaire together with the opportunity to provide written comments. This public consultation is part of the evaluation on administrative cooperation in the field of direct taxation (Council Directive 2011/16/EU).

…is part of the evaluation on administrative cooperation in the field of direct taxation (Council Directive 2011/16/EU). The objective of the consultation is to gather views from European citizens and stakeholders on their experience with the current rules governing administrative cooperation in direct taxation and the effects of that cooperation. KPMG1 is pleased to respond to the consultation. We have surveyed member firms within the EU and collated the responses in the questionnaire. (As the questionnaire only allows the respondent to state one country of origin we have put down the UK – although the responses also represent feedback from other Member States.) We also set out below some more information on a number of Member States Point of view from the Dutch Tax Authorities In the Netherlands international companies are generally well aware of the automatic exchange of information.

…the Netherlands international companies are generally well aware of the automatic exchange of information. They are fully up to date on country-by-country reporting and the exchange of advanced tax rulings within the EU by the Dutch tax authorities. 1 KPMG is a global network of professional services firms providing Audit, Tax and Advisory services. We operate in 154 countries and territories and have 200,000 people working in member firms around the world. The independent member firms of the KPMG network are affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. Each KPMG firm is a legally distinct and separate entity and describes itself as such. Ref.

…a Swiss entity. Each KPMG firm is a legally distinct and separate entity and describes itself as such. Ref. Ares(2019)6268003 - 10/10/2019 KPMG LLP KPMG Final Remarks to the European Commission’s Public Consultation on the functioning of the administrative cooperation in the field of direct taxation 1 March 2019 2 Document Classification - KPMG Confidential Companies are less aware of the exchange of information on request and spontaneous exchanges. Over the last few years the number of requests for information from other tax authorities has substantially increased. Point of view from the French taxpayers and their tax advisers The French tax authorities (FTA) are using information obtained from other national tax authorities for risk assessment / audit targeting purposes.

…are using information obtained from other national tax authorities for risk assessment / audit targeting purposes. The audit of international operations is no longer reserved to multi-national companies (MNCs) but is now targeted towards smaller taxpayers. When receiving the relevant information, the FTA are not required to inform French taxpayers. The FTA have been a driving force in building the exchange of information as a weapon against tax fraud and tax evasion and official statistics show that France is both one of the top senders and top receivers in regards to information exchanges. The FTA are expecting to use the possibilities to obtain information from third parties more often as requests for assistance from other tax authorities increases.

…to obtain information from third parties more often as requests for assistance from other tax authorities increases. The FTA still have to inform French taxpayers before the assessment is issued of the origin and content of the information and documents obtained from third parties on which it has relied to establish an adjustment (Article L. 76 B of the French tax procedure handbook). In this respect, the FTA’s legislative arsenal has significantly increased over the years and this is reflected in their new hearing power allowing FTA agents to collect information relating to certain aspects of international taxation.

…new hearing power allowing FTA agents to collect information relating to certain aspects of international taxation. However, in practice, as tax advisors, we have noted that: • While MNCs have been made aware of these practices (especially because of exchange of information on advanced tax rulings and advanced pricing arrangements) only a few comparatively smaller companies (that are not yet directly affected by the above-mentioned requirements) are aware of the exchange of information practices. • There is a lack of transparency in the way the FTA are using the information automatically gathered from the taxpayers and from the tax authorities. • Since there is no transparency or feedback on how this information is used, French taxpayers may be suspicious on how the information they provide to the FTA is treated.

…this information is used, French taxpayers may be suspicious on how the information they provide to the FTA is treated. • Traditionally, the tax obligation has been based on a bilateral tax administration/taxpayer relationship. However, this now includes financial institutions and other parties which results in a multitude of groups having to comply with information collection requirements.

…and other parties which results in a multitude of groups having to comply with information collection requirements. Therefore, the process would certainly be more efficient if: KPMG LLP KPMG Final Remarks to the European Commission’s Public Consultation on the functioning of the administrative cooperation in the field of direct taxation 1 March 2019 3 Document Classification - KPMG Confidential • Taxpayers could see how the information automatically collected by the tax authorities is used, analyzed, treated and interpreted in practice; • EU member States were to show that they adopt the same methodology in analyzing and interpreting the information collected.

States were to show that they adopt the same methodology in analyzing and interpreting the information collected. Indeed, and even if common rules are put in place for the automatic exchange of information, inconsistencies in analyzing and interpreting the collected data will lead, in the end, to inefficiencies in the treatment of similar situations within the EU; • EU Member States were to make public common analysis grids of the information automatically gathered. In the end, transparency and exchanges of information would need to be on both sides (taxpayers and tax authorities) and become bilateral. As far as France is concerned, this bilateral transparency approach would follow the same current development trends as the tax audit procedure. A new form of tax audit will be presented by the French government in the coming weeks.

…as the tax audit procedure. A new form of tax audit will be presented by the French government in the coming weeks. While a lot of information is still unknown on this topic, this new form of tax audit has been inspired by the UK and Dutch models and could be based on transparency: the taxpayer would present its own tax position and the FTA would approve it (or not). For this purpose, the taxpayer and the FTA would have to share all the information they have, including the information coming from automatic exchanges with other EU countries. Point of view from the Tax Authorities in Romania Even though Romania has limited multinational groups’ headquartered in-country, the tax authorities are tackling international tax risk topics such as transfer pricing and diverted profits and have increased audits in this area.

17 → 12

originalus šaltinis (PDF) ↗

To: European Commission DG TAXUD From: KPMG EU Transparency Register identification number: 65515368730-59 Date 11 September 2024 Ref KPMG contribution in response to the European Commission public consultation “Anti- Tax Avoidance Directive (ATAD) – evaluation ” Dear Madam / Sir, KPMG1 member firms in the European Union (“EU”) (hereafter “we”) are pleased to provide comments on the European Commission’s (“EC”) public consultation “Anti-Tax Avoidance Directive (ATAD) – evaluation” (the Consultation) on the Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market as amended by Council Directive (EU) 2017/952 of 29 May 2017 (ATAD or the Directive).

…of the internal market as amended by Council Directive (EU) 2017/952 of 29 May 2017 (ATAD or the Directive). We welcome the opportunity to comment on the implementation, functioning and future-proofing of the Directive, as well as its relevance in the current economic and regulatory environment. Our main comments can be summarized as follows: - The interaction of ATAD with the EU Minimum Tax Directive creates an additional level of complexity and has created a risk of double taxation, which should be addressed at EU level. In particular, we recommend that ATAD is amended to exempt from CFC regimes those groups that are in scope of Pillar Two.

…particular, we recommend that ATAD is amended to exempt from CFC regimes those groups that are in scope of Pillar Two. - Based on our practical experience with the application of ATAD, we note a number of areas where further clarity and certainty would be welcomed, such as with regard to the treatment of capitalized interest costs for the purposes of the interest limitation rules, and issues related to group taxation in the context of the anti-hybrid rules. - We also recommend that the adequacy of the deductibility threshold and de minimis rule and the scope of exclusions for long-term public infrastructure projects are revisited to better reflect the current economic environment and international environment. We address each of these points further below. 1 KPMG is a global organization of independent professional services firms providing Audit, Tax and Advisory services.

…1 KPMG is a global organization of independent professional services firms providing Audit, Tax and Advisory services. KPMG firms operate in 143 countries and territories with more than 265,000 partners and employees working in member firms around the world. Each KPMG firm is a legally distinct and separate entity and describes itself as such. This comment paper is produced on behalf of KPMG member firms located in the EU forming part of KPMG’s Europe, the Middle East & Africa (EMA) region. Throughout this submission, “we”, “KPMG”, “us” and “our” refer to the network of independent member firms operating in the EU. Ref. Ares(2024)6443626 - 11/09/2024 1.

…and “our” refer to the network of independent member firms operating in the EU. Ref. Ares(2024)6443626 - 11/09/2024 1. Interaction with EU Minimum Tax Directive The purpose of the consultation on the evaluation of ATAD is to provide evidence on the implementation of the Directive, to what extent its objectives have been achieved, and whether the measures need to be amended in the future. The “Call for evidence” includes considerations on the future-proofing of the measures, in particular their relevant taking into account the introduction of the Council Directive EU 2022/2523 on a global minimum level of taxation of 14 December 2022 (the “EU Minimum Tax Directive”). Both the ATAD and the EU Minimum Tax Directive serve similar policy objectives, which are fighting against aggressive tax planning and the prevention of profit shifting to low-tax jurisdictions.

…which are fighting against aggressive tax planning and the prevention of profit shifting to low-tax jurisdictions. The mechanics through which each of the two sets of rules aims to achieve these objectives are, however, different. The ATAD tackles specific anti-avoidance situations, by laying down minimum rules to address what are considered by regulators to be the most common forms of aggressive tax planning and tax avoidance practices affecting the EU internal market. The EU Minimum Tax Directive, on the other hand, transposes the OECD Global Anti-Base Erosion (GloBE) Model Rules (Pillar Two) into EU law and introduces a minimum effective corporate tax rate of 15 percent for multinational enterprise (MNE) and large-scale domestic groups in the EU.

…corporate tax rate of 15 percent for multinational enterprise (MNE) and large-scale domestic groups in the EU. The EU Minimum Tax Directive does not tackle specific tax avoidance situations, but is aimed at reducing the incentive for profits to be shifted to low- tax jurisdictions. In this context, we believe that it is of particular importance to take note of the high volume of new initiatives and the resulting administrative burden that both MNEs and EU tax administrations have been subject to in the past decade. With the introduction of the ATAD, and more recently the entry into force of the EU Minimum Tax Directive, taxpayers and tax authorities are having to understand and comply with an excessively high number of extremely complex requirements that are putting pressure on limited available resources.

…an excessively high number of extremely complex requirements that are putting pressure on limited available resources. In this section, we would like to address areas where the interaction of the two directives increases this level of complexity further and can potentially lead to overlaps resulting in double taxation. However, corporate groups with a revenue of more than EUR 750 million, may be subject to both directives, while these measures currently do not permit relief when such overlap would lead to double taxation. This goes beyond necessary to achieve the envisioned goals of the directives.

…overlap would lead to double taxation. This goes beyond necessary to achieve the envisioned goals of the directives. We note, in particular, the interaction between the controlled foreign company (“CFC”) rules based on Article 7 of the ATAD Directive on the one hand, and the Income Inclusion Rule (“IIR”) and the Qualified Domestic Top-up Tax (“QDMTT”) (as included in Chapter II of the EU Minimum Tax Directive), on the other. The GloBE rules establish an order of priority for the application of mechanisms of imposing tax on corporate profits, with the aim of achieving a minimum effective tax rate (ETR) of 15 percent, as follows: 2 A jurisdiction imposing a QDMTT has priority taxing rights over all others.

…tax rate (ETR) of 15 percent, as follows: 2 A jurisdiction imposing a QDMTT has priority taxing rights over all others. The numerator in a QDMTT ETR calculation should not include taxes paid to another jurisdiction under a CFC regime that otherwise would be allocable under the GloBE rules to a constituent entity located in that jurisdiction. This rule also applies in respect of any taxes paid by an owner of a permanent establishment in the jurisdiction. Instead, the parent jurisdiction imposing a CFC regime with respect to a low taxed constituent entity located in the QDMTT jurisdictions is expected to give a credit for a QDMTT imposed on the CFC, in step 2. To avoid circularity, any CFC taxes paid with respect to a low-taxed constituent entity are disregarded for the purposes of the QDMTT.

…any CFC taxes paid with respect to a low-taxed constituent entity are disregarded for the purposes of the QDMTT. Under step 3, CFC taxes are allocated to the relevant constituent entities for the purposes of determining whether any top-up tax remains to be collected through the IIR mechanism. As mentioned above, in order for the rules to produce the intended outcomes and to not lead to double taxation (whereby low-taxed profits are taxed twice – once under a QDMTT and the second time under a CFC regime), jurisdictions applying a CFC regime are expected to ensure that their CFC rules allow for a credit for any QDMTT paid with respect to the low-taxed entity.

…are expected to ensure that their CFC rules allow for a credit for any QDMTT paid with respect to the low-taxed entity. Indeed, some EU Member States (for example, Austria and Italy), have amended or are amending their CFC rules to specifically allow for such a credit, the majority of the other Member States (to the best of our knowledge) have not yet taken step to align their CFC rules with Pillar two. In this context, and in the interest of clarity and legal certainty, we believe that, at a minimum, the CFC rules in ATAD should be updated with a requirement for Member States to credit tax imposed under a QDMTT in a relevant jurisdiction, whether that jurisdiction is in or outside the EU. Absent such an amendment, there is a risk that EU jurisdictions do not apply a timely and consistent solution for the prevention of double taxation for groups that are in scope of both Directives.

31 → 12

originalus šaltinis (PDF) ↗

KPMG comments on Inception Impact Assessment on amendment to Council Directive 2011/16/EU on exchange of information to include crypto-assets KPMG1 member firms in the EU (hereafter “we”) are pleased to provide comments on the European Commission’s (EC’s) recent Inception Impact Assessment (Ref. Ares(2020)7030524 - 23/11/2020) initiated to explore the possibility of amendment of the Council Directive 2011/16/EU on exchange of information (‘the Directive’) to also include crypto-assets and e- money within its ambit We understand that the purpose of this amendment to the Directive is to monitor the assessment to tax of income derived from the holding and transfer of crypto-assets, as well as of e-money, in order to reduce tax evasion, while striving to alleviate the compliance burdens related to reporting and exchange of information.

…tax evasion, while striving to alleviate the compliance burdens related to reporting and exchange of information. There is an increasing proliferation of crypto-assets as an acceptable means of commercial exchange as well as an investment, and this is giving rise to interest in regulation across jurisdictions, including at institutional level by the OECD. We agree that including crypto- currencies within the Directive is an appropriate initial step which may lead to including them within existing and new financial regulations. However, as this is a dynamic area, we submit that the principles of subsidiarity and proportionality should be the drivers when scoping out the Directive amendments.

…the principles of subsidiarity and proportionality should be the drivers when scoping out the Directive amendments. We believe it is of vital importance that this objective is balanced with the need for the EU to remain an attractive avenue for business, which in turn would reap greater revenues, thus addressing investor and business compliance concerns. We recommend a clear definition of crypto-assets be included in the Directive, including a distinction among the diverse types of crypto-assets. This should facilitate certainty, consistency and uniformity across the EU. Differentiation of various classes of assets based on their utilization, technological design and core characteristics could enable the targeting and limitation of the scope of exchange of information based on their different risk profiles.

…enable the targeting and limitation of the scope of exchange of information based on their different risk profiles. This could help ensure that the proposed expansion and implementation of the Directive is simplified and targeted to meet the desired objectives, without undue burden on low-risk investments and transactions. To this point, we believe that a thorough initial risk assessment should assist the determination whether e-money and stablecoins should, at the outset, feature in this amendment. We recommend also that crypto-assets are defined bearing in mind technological processes and advancements, with the intention of ensuring that any legislative or regulatory intervention is dynamic, and remains pertinent to emerging technologies as they evolve.

…any legislative or regulatory intervention is dynamic, and remains pertinent to emerging technologies as they evolve. This requirement for precise scoping is also relevant for determining which intermediaries would be tasked with reporting, and whether the taxpayer should have the ultimate reporting liability in cases where no intermediaries are involved. It would be essential for effectiveness that the underlying technological processes and the roles of the various service providers are clearly identified and defined. To ensure such analysis is effected, we believe that detailed 1 KPMG is a global organization of independent professional services firms providing Audit, Tax and Advisory services. KPMG operates in 147 countries and territories and has more than 219,000 people working in member firms around the world.

…operates in 147 countries and territories and has more than 219,000 people working in member firms around the world. Each KPMG firm is a legally distinct and separate entity and describes itself as such. This comment paper is produced on behalf of KPMG member firms located in the EU forming part of KPMG’s Europe, the Middle East & Africa (EMA) region. Ref. Ares(2020)7824585 - 21/12/2020 consultation with relevant service providers and the business community should be undertaken. Further, we would recommend that any action is aligned with ongoing work being undertaken by the OECD and the FATF on the regulation of cryptocurrencies. In keeping with the General Data Protection Regulation (EU) 2016/679 (‘GDPR’), the nature of the reportable information should not exceed what is necessary to achieve the objectives of the Directive amendment.

…the reportable information should not exceed what is necessary to achieve the objectives of the Directive amendment. Such limitation on the data to be reported, in line with existing guidance under the GDPR would also assist tax administrations in managing the data received and in exchanging said data, where necessary. Last but not least, we believe that an assessment of the resources available to tax administrations in the Member States should inform the Commission of the current and expected capacity. This is important when formulating timelines, particularly for the introduction of exchange of information obligations. We trust that you find our above inputs useful. We remain available to work with the Commission in helping realize the objective of fair and transparent taxation framework across EU Member States.

…the Commission in helping realize the objective of fair and transparent taxation framework across EU Member States. Juanita Brockdorff Partner, Tax Services, Distributed Ledger and Emerging Technology ([email protected]) 21 December 2020 CC Gyöngyi Vegh, KPMG Tax & Legal Advisers, Brussels ([email protected])

originalus šaltinis (PDF) ↗

Dear Madam/ Sir, KPMG1 member firms in the EU (hereafter ‘we’) are pleased to provide comments on the European Commission’s (EC’s) consultation initiated to explore the possibility of amendment of the Council Directive 2011/16/EU on exchange of information (‘the Directive’) to also include crypto-assets and e- money within its ambit. We understand that the purpose of this amendment to the Directive is to monitor the assessment to tax of income derived from the holding and transfer of crypto-assets, as well as of e-money, in order to reduce tax evasion, while striving to alleviate the compliance burdens related to reporting and exchange of information. We reiterate that the principles of subsidiarity and proportionality should be the drivers when scoping out the Directive amendments.

…the principles of subsidiarity and proportionality should be the drivers when scoping out the Directive amendments. We believe it is of vital importance that this objective is balanced with the need for the EU to remain an attractive avenue for business, which in turn would reap greater revenues, thus addressing investor and business compliance concerns. The introduction of disclosure and exchange requirements in terms of this amendment stands on two pillars, namely the extension of the definition of the term “intermediary” and the introduction of “crypto assets” and “e-money”.

…the extension of the definition of the term “intermediary” and the introduction of “crypto assets” and “e-money”. We submit that the scope should align with the updates to the FATF guidance in relation to crypto-assets, the amendments to the Anti-Money Laundering Directive, in particular AMLD5 (although the latter singles out virtual currencies), as well as the upcoming OECD Common Reporting Standard update in relation to crypto assets. We believe that a gradual, considered approach would have better prospects for alignment, certainty in application and stability from an investor/market perspective.

…would have better prospects for alignment, certainty in application and stability from an investor/market perspective. “Crypto assets” and “e-money” The proposal for an EU Regulation on Markets in Crypto-assets (MICA) published in September 2020 already includes a definition of crypto assets, namely “a digital representation of value or rights which may be transferred and stored electronically, using distributed ledger technology or similar 1 KPMG is a global organization of independent professional services firms providing Audit, Tax and Advisory services. KPMG operates in 147 countries and territories and has more than 219,000 people working in member firms around the world. Each KPMG firm is a legally distinct and separate entity and describes itself as such.

…member firms around the world. Each KPMG firm is a legally distinct and separate entity and describes itself as such. This comment paper is produced on behalf of KPMG member firms located in the EU forming part of KPMG’s Europe, the Middle East & Africa (EMA) region. To: European Commission, DG TAXUD, Unit D1 secretariat, SPA3 08/015, B-1049 Brussels, Belgium From: KPMG EMA Cooperative Bederstrasse 66 Zurich CH-8027 Switzerland EU Transparency Register identification number: 65515368730-59 Date 2 June 2021 Ref KPMG Response to the European Commission Consultation on the Proposal for Council Directive amending Directive 2011/16/EU to expand and include crypto-assets and e-money Ref. Ares(2021)3695117 - 04/06/2021 technology”. Ensuring alignment through the use of one definition requires that the definition is fit for more than one purpose, which at present is doubtful.

…the use of one definition requires that the definition is fit for more than one purpose, which at present is doubtful. In the context at hand, this definition gives rise to a number of open issues. Primarily, the broad wording of the definition encompasses assets that do not necessarily have a cryptographic element. In this respect, we submit that a distinction ought to be made between a ‘digital representation’ and a ‘cryptographic representation’, also to avoid overlap with previous amendments to the Directive, given that the phrase ‘or similar technology’ is not sufficient to ensure clarity. To this point, the introduction of e-money in this amendment is understood to also extend to e-money tokens as defined in the MICA, such as stablecoins, and is therefore intended to address any loopholes in reporting obligations.

…defined in the MICA, such as stablecoins, and is therefore intended to address any loopholes in reporting obligations. Further, the diverse nature of the entitlement arising from the holding or from transactions with different crypto assets begs a distinction among the diverse types of crypto-assets in keeping with the context of sharing information for tax purposes. Differentiation of various classes of assets based on their utilization, technological design and core characteristics could enable the targeting and limitation of the scope of exchange of information based on their different risk profiles. This could help ensure that the proposed expansion and implementation of the Directive is simplified and targeted to meet the desired objectives, without undue burden on low-risk investments and transactions.

…simplified and targeted to meet the desired objectives, without undue burden on low-risk investments and transactions. The definition also fails to distinguish between centralised and decentralised crypto systems. The replication of a centralised approach is notable throughout the questionnaire and is expected to create significant difficulties in application and enforcement of the Directive. Decentralisation was the original intention behind distributed ledger technologies and is expected to become the norm. We recommend that a deeper assessment of the application of reporting obligations on decentralised systems is undertaken to ensure a considered approach.

…of the application of reporting obligations on decentralised systems is undertaken to ensure a considered approach. We recommend also that crypto-assets are defined bearing in mind technological processes and advancements, with the intention of ensuring that any legislative or regulatory intervention is dynamic, and remains pertinent to emerging technologies as they evolve. “Intermediary” This requirement for precise scoping is also relevant for determining which intermediaries would be tasked with reporting, and whether the taxpayer should have the ultimate reporting liability in cases where no intermediaries are involved. It would be essential for effectiveness that the underlying technological processes and the roles of the various service providers are clearly identified and defined.

…underlying technological processes and the roles of the various service providers are clearly identified and defined. In this vein, to ensure a level playing field across regulated sectors, it is expected that reporting obligations would apply to equivalent service providers and tax points, rather than be extended to anyone who has a touch point with crypto assets. We submit that once crypto assets become regulated across jurisdictions, including through MICA and at institutional level by the OECD, the industry would become more structured and synchronised, enabling the regulator to better achieve its objectives while respecting the inherent nature and purpose of distributed ledger technology and similar. In the meantime, over-regulation in terms of exchange of information may not have the desired impact on the industry.

In the meantime, over-regulation in terms of exchange of information may not have the desired impact on the industry. It would be more effective to incentivise self-assessment through education, and encourage the increase of ‘intermediaries’ by legitimising the sector, thus increasing regulated crypto (and digital in a broader sense) activity through centralisation. The way forward is Industry 4.0 – how is tax cooperation to develop without aligning with the intrinsic character of the technology itself? Questionnaire With specific reference to the questions posed, while we have attempted to reflect our feedback in the attached Questionnaire, we set out some further considerations below.

…we have attempted to reflect our feedback in the attached Questionnaire, we set out some further considerations below. Question 9 With respect to the frequency of information relative to transactions that would be most suitable for standardized reporting by crypto-asset service providers, we propose assessing to what extent tax authorities would appreciate the efficiency of APIs (application programming interfaces) which are essentially script written into the code which enables an authorised person to view an audit trail of the information required at any time. Question 12 The replies to the statements depend on the jurisdiction that is being assessed. Some jurisdictions have introduced regulation while others have not. Self- assessment tax disclosure obligations apply equally to trade and investment across reportable assets.

19 → 12

originalus šaltinis (PDF) ↗