1. ISSUES AND CHALLENGES FACING TAX ADMINISTRATIONS The perspective of Tax Administrations
EU Commission – DG TAXUD – Morgan Guillou 14 April 2015

2. 1. Existing practical tools Automatic exchange of information (AEOI)
EU experience and evolution over recent years
MAD: EU Mutual Assistance Directive
Adoption: 1977 – Application: 1979
EUSD: EU Savings Directive
Proposal: 2001 – Adoption: 2003 – Application: 2005
Adoption revision: 2014 – Application revision: 2017
DAC1: EU Directive on Administrative Cooperation 1
Proposal: 2009 – Adoption: 2011 – Application: 2015
Content: available information on income from employment, director’s fees, immovable property, pensions, life insurance products
DAC2: EU Directive on Administrative Cooperation 2
Proposal: 2014 – Adopted: 2014 – To be applied: 2017/2018
Content: interest, dividends, capital gains, account balances …
DAC3: EU Directive on Administrative Cooperation 3
Proposal: March 2015
Content: tax transparency package (rulings)
Operating Transfer Pricing rules in the New Transparent Environment: Exploiting the Potential of New Technologies – Vienna April 2015

3. 1. Existing practical tools Automatic exchange of information (AEOI)
4 basic but very different tax activities
1. Tax collection and treatment 3 4
2. Request for information 2 1
3. Automatic exchange of information
4. Matching and use of information received from AEOI
Operating Transfer Pricing rules in the New Transparent Environment: Exploiting the Potential of New Technologies – Vienna April 2015

4. 1. Existing practical tools Focus on tax transparency package
Operating Transfer Pricing rules in the New Transparent Environment: Exploiting the Potential of New Technologies – Vienna April 2015

5. 1. Existing practical tools Focus on tax transparency package
Operating Transfer Pricing rules in the New Transparent Environment: Exploiting the Potential of New Technologies – Vienna April 2015

6. 1. Existing practical tools Focus on Country by Country Reporting
2013: EU Heads of State agreed to CbCR for tax purposes at the special summit on tax evasion
Current state of play:
CRD IV – Credit institutions & investment firms
Extractive and forest industries
What's coming next?
Operating Transfer Pricing rules in the New Transparent Environment: Exploiting the Potential of New Technologies – Vienna April 2015

7. 2. Future steps Transparency Package EU Transfer pricing framework
Improving existing EU instruments and standards ; developing new ones
Facilitate implementation and support Member States in this respect
Focus on simplification, clarification and fiscal consolidation
Operating Transfer Pricing rules in the New Transparent Environment: Exploiting the Potential of New Technologies – Vienna April 2015