International Tax and Company Planning.

International tax and company planning represents increasingly one of the most important areas for professionals and companies that operate in the international arena and have to face laws and tax systems which, even within the European Union, are not uniform among the various countries.

This kind of variety among the various countries often derives from the different matrix of legal systems, one need only think of the substantial differences between the “Common Law” and the “Civil Law” countries, but also the fact that it does not often exist, in relation to some legal concepts, a uniqueness even in terms of definition (we could mention the concepts of residency and domicile).

Such differences have clearly practical implications regarding the application of the OECD multilateral agreements, which represent an essential reference point in the specific international regulatory framework for some years.

It is an international regulatory framework whose knowledge is necessary to the professional who has to guide his clients in an increasingly complex environment in which the entry into force of OECD conventions with acronyms like MAAT, CRS, BEPS, imposes a radical change in the approach to international business.

In this context, it is always more important to be supported by an international network that, through its direct presence in various jurisdictions, can effectively sustain professionals and entrepreneurs in developing foreign activities in absolute legality,  and at the same time, pursuing the highest standards in terms of efficiency in the tax field.

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Transnational Information Exchange. From August 21, 2017, a New Age begins.

On August 21, the automatic transnational exchange of informations for tax purposes will begin in 54 countries (called early adopters).

In 2018, 50 countries will be added to the existing ones and, starting from the following years other countries will be included according to the OECD plan.

The 21st of August 2017 symbolically represents the end of an era, the epoch of national sovereignty over financial information, and the beginning of another one characterized by globalization in tax matters.

It will be the date in which banks in the 54 early adopters countries will have to send to their respective tax administrations the data of their foreign clients which, from the following month, the administrations will exchange with each other according to the parameters defined from OECD .

In other words, what has already happened in Italy with the acquisition of all taxpayers’ data in the huge database of “Agenzia delle Entrate”, will happen at international level.

All this amount of data obviously requires long technical times, considering also that information coming from different countries are not always orderly and accurate.

There is no doubt, however, that this is an irreversible process that has radically changed the world we live in.

It is worth pointing out that the process of financial globalization can be completed only if the United States choose to be an active part of this exchange system.

Indeed, the United States, which have pushed with great strength to get this kind of transnational informations exchange (the FATCA came into force before the OECD Common Reporting Standard), have based the process on one-way bilateral agreements (FATCA does not provide for reciprocity). In essence, all the countries must transmit information about American citizens to USA, but the USA does not have the obligation to reciprocate in the exchange of data.

This situation leads the USA to be the most important “tax haven” with an attractiveness from all over the world thanks to the secrecy guaranteed in Wyoming, Nevada, Virginia or Delaware and the opportunity to use companies such as LLCs, very simple to shield.

Anyway, it is certain that the road to total globalization of informations has already been traced and nothing will ever be the same again.

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