GUERNSEY STEP MARK SAVAGE 11 January 2017 UK TAX UPDATE GUERNSEY STEP MARK SAVAGE 11 January 2017 Introduction The guidance notes included in this template are intended to assist you in creating successful PowerPoint slide presentations. In order to reduce the amount of time it takes to create a presentation, colours, fonts, the position of the locator graphic device and various graphic elements have been programmed into the templates. This means that the creation of most slides is automated. When printing to ‘black and white’, all colour elements will be converted to grayscale. You can preview how your presentation will print ‘black and white’ by choosing the preview option under the ‘view’ menu in PowerPoint. Title slide (Slide layout option: Title Slide) The title slide is preset in style by the ‘title master’. Graphic elements are fixed in position on the typographic grid. Text, which is also fixed in size and position, can be edited but should not be resized or the colour changed. The title slide master includes the BDO Teal colour as a background. This can be changed to any of the colours from the template’s colour palette except BDO Grey. BDO Blue, BDO Teal, BDO Burgundy, BDO Copper and BDO Fuchsia are all acceptable. Text should always be white. See also image title slide option (next slide)

FATCA - Presentation to Praxis CONTENTS Section divider (Slide layout option: Divider-teal) The section divider slide is an effective way of breaking up your presentation into chapters. Five section dividers have been included in this template, all following the same style but each one having a distinct BDO colour. Section divider slides are for this use ONLY and should never be adapted to create additional slide types or styles. Divider headings – Trebuchet MS bold, 32 pt, upper case, white Sub-headings – Trebuchet MS bold, 18 pt, upper case, white FATCA - Presentation to Praxis

UK TAX UPDATE Contents Corporation Tax Personal Taxes Other Taxes Anti-avoidance Questions Text slide with title, body text and bulleted text levels (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within the text box there are four levels of text: Level 1 – Body text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. Subsequent lines of copy do not have an indent on this text level. Level 2 –Bulleted text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are round and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Third level – Bulleted text set in 14pt. Trebuchet MS Regular with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Fourth level – Bulleted text set in 14pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and are in BDO Grey and subsequent lines of text are indented to maintain text alignment. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary.

FATCA - Presentation to Praxis CORPORATION TAX Section divider (Slide layout option: Divider-teal) The section divider slide is an effective way of breaking up your presentation into chapters. Five section dividers have been included in this template, all following the same style but each one having a distinct BDO colour. Section divider slides are for this use ONLY and should never be adapted to create additional slide types or styles. Divider headings – Trebuchet MS bold, 32 pt, upper case, white Sub-headings – Trebuchet MS bold, 18 pt, upper case, white FATCA - Presentation to Praxis

CORPORATION TAX Property Development Treaty Protection removed from 16 March 2016 Development of UK property now a UK trade carried on through a PE Subject to corporation tax / income tax Effective from 5 July 2016 (subject to anti-forestalling) Treatment of “planning gain” as part of development Anti-avoidance rules around “fragmentation” CGT treatment remains for investment properties Not subject to UK tax unless NRCGT or ATED apply (residential properties only) Text slide with title, body text and bulleted text levels (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within the text box there are four levels of text: Level 1 – Body text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. Subsequent lines of copy do not have an indent on this text level. Level 2 –Bulleted text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are round and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Third level – Bulleted text set in 14pt. Trebuchet MS Regular with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Fourth level – Bulleted text set in 14pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and are in BDO Grey and subsequent lines of text are indented to maintain text alignment. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary.

CORPORATION TAX Interest deductions From April 2017 Corporation tax only “Net” interest expense De minimis of £2m Deduction limited to 30% tax-EBITDA (excludes FV movements) 5 year carry forward Group limitation (Worldwide group’s 3rd party interest cover) Public interest exemption (large infrastructure projects) Transfer pricing / thin cap rules remain WWDC replaced Text slide with title, body text and bulleted text levels (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within the text box there are four levels of text: Level 1 – Body text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. Subsequent lines of copy do not have an indent on this text level. Level 2 –Bulleted text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are round and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Third level – Bulleted text set in 14pt. Trebuchet MS Regular with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Fourth level – Bulleted text set in 14pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and are in BDO Grey and subsequent lines of text are indented to maintain text alignment. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary.

CORPORATION TAX Other Points Rate 19% from April 2017; 17% by 2010 Loans to participators Rate now 32.5% Loss Relief Allowed against all sources of income (post-April 2017 losses) Only 50% of profits (post-April 2017) can be sheltered by b/fwd losses (£5m group de minimis) Patent box R&D / development of IP must be in UK (from April 2017) – BEPS related SSE “Trading” requirements relaxed Text slide with title, body text and bulleted text levels (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within the text box there are four levels of text: Level 1 – Body text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. Subsequent lines of copy do not have an indent on this text level. Level 2 –Bulleted text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are round and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Third level – Bulleted text set in 14pt. Trebuchet MS Regular with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Fourth level – Bulleted text set in 14pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and are in BDO Grey and subsequent lines of text are indented to maintain text alignment. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary.

FATCA - Presentation to Praxis PERSONAL TAXES Section divider (Slide layout option: Divider-teal) The section divider slide is an effective way of breaking up your presentation into chapters. Five section dividers have been included in this template, all following the same style but each one having a distinct BDO colour. Section divider slides are for this use ONLY and should never be adapted to create additional slide types or styles. Divider headings – Trebuchet MS bold, 32 pt, upper case, white Sub-headings – Trebuchet MS bold, 18 pt, upper case, white FATCA - Presentation to Praxis

PERSONAL TAXES Offshore pensions Temporary Non-Resident rules extended to UK pensions drawn by Non-Residents Loss of 10% deduction for overseas pensions received by UK Residents Tightening of criteria to become QROPS Extension of period fund must be in a QROPS from 5 to 10 years before UK relinquishes taxing rights Text slide with title, body text and bulleted text levels (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within the text box there are four levels of text: Level 1 – Body text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. Subsequent lines of copy do not have an indent on this text level. Level 2 –Bulleted text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are round and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Third level – Bulleted text set in 14pt. Trebuchet MS Regular with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Fourth level – Bulleted text set in 14pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and are in BDO Grey and subsequent lines of text are indented to maintain text alignment. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary.

PERSONAL TAXES Non-Domiciliaries Deemed domicile now 15/20 years for all taxes UK born individuals with UK domicile of origin automatically deemed domiciled On reacquiring UK residence Excluded property trusts still valid Business Investment Relief expanded Foreign income not treated as remitted if invested in UK business “Look through” offshore companies to UK residential property Effective 6 April 2017 Carried Interest No base cost shift Taxed in UK if services in UK Text slide with title, body text and bulleted text levels (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within the text box there are four levels of text: Level 1 – Body text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. Subsequent lines of copy do not have an indent on this text level. Level 2 –Bulleted text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are round and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Third level – Bulleted text set in 14pt. Trebuchet MS Regular with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Fourth level – Bulleted text set in 14pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and are in BDO Grey and subsequent lines of text are indented to maintain text alignment. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary.

PERSONAL TAXES Other Points Personal Allowances (£11,000 for 16/17 - £11,500 for 17/18) CGT Rates (now 10% or 20% except residential property – still 18/28%) Trust rate 20% (28% for residential property) Dividend tax rates £5k exemption 7.5%, 32.5%, 38.1% (trustees 38.1%) No tax credit Abolition of Class 2 NICs Salary Sacrifice ESS Abolished Text slide with title, body text and bulleted text levels (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within the text box there are four levels of text: Level 1 – Body text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. Subsequent lines of copy do not have an indent on this text level. Level 2 –Bulleted text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are round and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Third level – Bulleted text set in 14pt. Trebuchet MS Regular with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Fourth level – Bulleted text set in 14pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and are in BDO Grey and subsequent lines of text are indented to maintain text alignment. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary.

FATCA - Presentation to Praxis OTHER TAXES Section divider (Slide layout option: Divider-teal) The section divider slide is an effective way of breaking up your presentation into chapters. Five section dividers have been included in this template, all following the same style but each one having a distinct BDO colour. Section divider slides are for this use ONLY and should never be adapted to create additional slide types or styles. Divider headings – Trebuchet MS bold, 32 pt, upper case, white Sub-headings – Trebuchet MS bold, 18 pt, upper case, white FATCA - Presentation to Praxis

OTHER TAXES IPT now 10% (12% from April 2017) SDLT on 2nd homes: 3% supplement Text slide with title, body text and bulleted text levels (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within the text box there are four levels of text: Level 1 – Body text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. Subsequent lines of copy do not have an indent on this text level. Level 2 –Bulleted text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are round and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Third level – Bulleted text set in 14pt. Trebuchet MS Regular with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Fourth level – Bulleted text set in 14pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and are in BDO Grey and subsequent lines of text are indented to maintain text alignment. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary.

FATCA - Presentation to Praxis ANTI-AVOIDANCE Section divider (Slide layout option: Divider-teal) The section divider slide is an effective way of breaking up your presentation into chapters. Five section dividers have been included in this template, all following the same style but each one having a distinct BDO colour. Section divider slides are for this use ONLY and should never be adapted to create additional slide types or styles. Divider headings – Trebuchet MS bold, 32 pt, upper case, white Sub-headings – Trebuchet MS bold, 18 pt, upper case, white FATCA - Presentation to Praxis

ANTI-AVOIDANCE Requirement To Correct Compulsion not amnesty Applies to individuals who have failed to notify of need to file, failed to file or filed incorrect returns up to 2015/16 (or 16/17?) Disclosure by 30 September 2018 Disclose using existing (5 year) time limit Limited to “offshore” matters Failure to correct: Extend enquiry time limits Penalty regime – consultation Up to 200% penalty / asset based penalty Name & shame Text slide with title, body text and bulleted text levels (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within the text box there are four levels of text: Level 1 – Body text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. Subsequent lines of copy do not have an indent on this text level. Level 2 –Bulleted text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are round and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Third level – Bulleted text set in 14pt. Trebuchet MS Regular with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Fourth level – Bulleted text set in 14pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and are in BDO Grey and subsequent lines of text are indented to maintain text alignment. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary.

ANTI-AVOIDANCE Enablers of Offshore Evasion From 1 January 2017 Enabler: encouraged, assisted or facilitated offshore evasion or non-compliance Not only criminal evasion Penalties for failure to notify, file or incorrect returns (simple error!) Penalties for offshore asset moves Enabler’s knowledge at time of act / omission Knowledge not relevant for asset moves Penalty 100% of tax at risk (50% for asset moves) Reduction for co-operation but 10% minimum penalty Subject to special circumstances Naming & shaming High value or serial offenders Corporate criminal offence for “failure to prevent” (proposed) Text slide with title, body text and bulleted text levels (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within the text box there are four levels of text: Level 1 – Body text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. Subsequent lines of copy do not have an indent on this text level. Level 2 –Bulleted text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are round and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Third level – Bulleted text set in 14pt. Trebuchet MS Regular with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Fourth level – Bulleted text set in 14pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and are in BDO Grey and subsequent lines of text are indented to maintain text alignment. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary.

ANTI-AVOIDANCE Other Points Disclosure of Tax Avoidance Schemes (DOTAS) Inclusion of “financial products” hallmark Wide definition From February 2016 Strict liability offence for offshore non-compliance Benefit of CRS Notifying HMRC of complex offshore structures Consultation Dividend treatment (capital or revenue) Only relevant to UK taxpayers Text slide with title, body text and bulleted text levels (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within the text box there are four levels of text: Level 1 – Body text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. Subsequent lines of copy do not have an indent on this text level. Level 2 –Bulleted text set in 18pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are round and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Third level – Bulleted text set in 14pt. Trebuchet MS Regular with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and in BDO Grey and subsequent lines of text are indented to maintain text alignment. Fourth level – Bulleted text set in 14pt. Trebuchet MS Regular in BDO Grey with single line spacing. This also includes preset additional .2 line spacing which appears between paragraphs. All bullet points are en dashes and are in BDO Grey and subsequent lines of text are indented to maintain text alignment. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary.

FATCA - Presentation to Praxis QUESTIONS? Section divider (Slide layout option: Divider-teal) The section divider slide is an effective way of breaking up your presentation into chapters. Five section dividers have been included in this template, all following the same style but each one having a distinct BDO colour. Section divider slides are for this use ONLY and should never be adapted to create additional slide types or styles. Divider headings – Trebuchet MS bold, 32 pt, upper case, white Sub-headings – Trebuchet MS bold, 18 pt, upper case, white FATCA - Presentation to Praxis

BIOGRAPHY MARK SAVAGE Tax Director mark.savage@bdo.gg Mobile: 07781 427072 BDO LIMITED PO Box 180, Place du Pré Rue du Pré, St Peter Port Guernsey GY1 3LL Tel: 01481 724561 Fax: 01481 711657 Biography slide (Slide layout option: Biography) Replace the sample text with the individual’s details using the heading titles given in the sample text, beginning with the person’s name, title, email address and contact details. Click the image box to insert an approved image of the individual and align the image to fit the typographic grid. Please refer to imagery guidelines for portrait photography guidance.

Disclaimer: This presentation contains general information only and BDO Limited is not, by means of this presentation rendering accounting, business, financial, investment, legal, tax or other professional advice or services. This presentation is not suitable for such professional advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified adviser. BDO Limited or its affiliates and related entities shall not be responsible for any loss suffered by any person who relies upon this presentation © BDO Limited 2017