1. S18 & EUSD

2. Background to EUSD Cross border tax evasion in the EU Cross border tax evasion in the EU Threat of EU-wide WHT Threat of EU-wide WHT Exchange of information Exchange of information Some countries impose WHT Some countries impose WHT Knee-jerk reaction Knee-jerk reaction What consultation? What consultation?

3. Two sets of rules in one report Rules are confusing – (especially if you deal with QI as well) Rules are confusing – (especially if you deal with QI as well) Unit Trusts/Collectives Unit Trusts/Collectives PEPs/ISAs/CTFs PEPs/ISAs/CTFs Joint accounts Joint accounts Trusts Trusts What harmonisation could be done? What harmonisation could be done?

4. DOCUMENTATION - EUSD The language problem The language problem Which number is the TIN? Which number is the TIN? Reluctance for sending originals Reluctance for sending originals Problems of certification Problems of certification Why use the term TIN? Why use the term TIN? Client confusion Client confusion Confusion for people in non-EU countries Confusion for people in non-EU countries

5. What do the local tax authorities do with the information? TIN TIN Place & date of birth Place & date of birth Costs & Benefits Costs & Benefits

6. Audit experience S18 audit for 2004/5 S18 audit for 2004/5 Penalties Penalties

7. Tax collected in 6 Months Switzerland £69m Switzerland £69m Jersey £9m Jersey £9m Guernsey £3m Guernsey £3m Where has all the taxable income gone?

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

9. IS ANYONE AWARE OF: The mandatory requirement for Authorised Investment Funds to pay Distributions Gross to so-called No-Net Liability Taxpayers? The mandatory requirement for Authorised Investment Funds to pay Distributions Gross to so-called No-Net Liability Taxpayers?