Professional Documents
Culture Documents
Transform Today For Challenges of Tomorrow
Transform Today For Challenges of Tomorrow
the challenges of
tomorrow
Plenary
Maison de L’automobile
15 December 2015
Andre Claes – Partner, Deloitte Belgium
Mark Kennedy – Partner, Deloitte UK
Patrick Joucken – Partner, Deloitte Belgium
1
Contents
Introduction
Transformation – why?
Conclusion
Introduction
Transformation?
Bill Gates
Chairman and CEO of Microsoft
Transform today for
the challenges of
tomorrow
Transformation –
why?
6
Transformation why?
External trends are impacting Tax …
As business GLOBALIZES … so do tax Increased REGULATION makes business
obligations together with a pressure for more complex but also more transparent
centralized global delivery ... raising risk and enabling mainstream
media coverage
8
The story so far
9
International response
Unilateral measures
10
What does it mean?
11
The Global Tax Reset & BEPS
Country-by-country reporting (CbCR)
This perspective paper aggregates frequently asked
questions by business leaders about Country-by-
country reporting (CbCR), a requirement detailed in
Global Tax Reset: the changing world of tax
Action 13 of the OECD's BEPS guidelines, and is
The Global Tax Reset is bringing in a new era of
intended to help companies understand what CbCR
international tax, with an emphasis on transparency,
is, what information is needed, who CbCR applies to,
consistency and sharing of information between tax
and how businesses can prepare.
authorities. This paper discusses the forces driving
significant change to the international tax landscape,
as well as key areas of business impact and BEPS Actions
resulting challenges. There are 15 BEPS Actions that are currently being
considered and worked on by the OECD. For each of
the Actions, there are factors to consider such as the
About BEPS and FAQs timing, impact and potential impact on policy. The
The OECD’s Base Erosion and Profit Shifting actions OECD/G20 has set a number of deadlines to
are well underway with proposals and consultations conclude on the BEPS Actions.
on all actions. Change is coming. These pages will
help businesses navigate what is happening, key
deadlines and issues they might want to consider. G20/OECD Timeline
An overview of the information and documentation
that has been released by the OECD during the
Articles, briefings and discussion papers course of the BEPS Action Plan, together with
The OECD’s Base Erosion and Profit Shifting actions relevant Deloitte or third party content and
are well underway with proposals and consultations commentary. As well as containing details of all of
on all actions. Change is coming. These pages will the releases to date, the timeline shows what is
help businesses navigate what is happening, key expected over the coming months, in accordance
deadlines and issues they might want to consider. with the schedule published by the OECD.
12
Transform today for
the challenges of
tomorrow
Transformation –
what and how?
13
Tax transformed – the “professionalisation” of tax
Report Risks
Tax Vision, Goals People and Processes
Risk Tax Outputs and
organisation
and Strategy appetite Communication
Systems
Oversight Decision
Test Controls making
Control
Accountabilities standards
14
Tax policy,
risk and operations
15
Increasing formalisation of tax policy
Groups are increasingly defining their tax policy Accountabilities for taxes getting clearer
No
23%
29%
Yes, for some areas
16
Answering key questions
Report Risks
Tax Vision, Goals People and Processes
Risk Tax Outputs and
organisation
and Strategy appetite Communication
Systems
Test Controls Decision
Oversight
making
Control
• The Press
Report Risks
Tax Vision, Goals People and Processes
Risk Tax Outputs and
organisation
and Strategy appetite Communication
Systems
Test Controls Decision
Oversight
making
Control
20
Global tax operating models
21
Increasingly centralised decision-making
Global tax operating models: past, present and future
Report Risks
Tax Vision, Goals People and Processes
Risk Tax Outputs and
organisation
and Strategy appetite Communication
Systems
Test Controls Decision
Oversight
making
Control
25
Tax Department is a large consumer of data
27
© 2015 Deloitte Belgium
Tax transformation framework
Global direct tax
Global indirect tax
Accounting for tax (provision) People
and
organization
Regulatory compliance
Data and
information
Enablers
28
Value drivers
Conclusion
29
Conclusion
Main points?
1. Policy, Risk and Operations
2. Compliance Operating models
3. Technology
30
Conclusion
Agenda of the day
31
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee (“DTTL”), its network of member firms, and their related entities.
DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as “Deloitte Global”) does not provide services to clients. Please see
www.deloitte.com/about for a more detailed description of DTTL and its member firms.
Deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member
firms in more than 150 countries and territories, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most
complex business challenges. Deloitte’s more than 200,000 professionals are committed to becoming the standard of excellence.
This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the “Deloitte
Network”) is, by means of this communication, rendering professional advice or services. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained
by any person who relies on this communication.
1
Contents
1. Definition
3. Solution Framework
5. Summary
1. Definition
3
Definition
Transfer
pricing policy
People, Processes and
Technology employed to
ensure that chosen
business model and
transfer pricing policies are Operational TP
ultimately reflected in its Monitoring Implementation
books and statutory returns
Documen-
tation
2. Issues &
Challenges
5
Issues & Challenges
• TP policy not shared within the organization • No possibility to split P/L per function / profit
and / or not properly followed in practice center / transaction / ...
• Unclear roles and responsibilities: tax team • Inconsistent definitions of P/L elements
often not aware of altered IC transactions • Limited ability to monitor and adjust global
• Disconnect between tax department & other pricing on a monthly or quarterly basis
business departments → Substantial year-end adjustments (creates
• A complex and fragmented architecture with awareness at the level of the authorities)
multiple (ERP) systems • Potential impact on tax (management), both
• A wide variety of GAAP and accounting direct taxes as well as indirect taxes
systems
→ No standardized chart of accounts
• Reliance on a large number of spreadsheets
(highly manual, prone to error)
3. Solution
Framework
7
Solution Framework – Key considerations
Priorities
Policies are Data collection is Calculations and Reporting and Policy or calculation
Audit status is visible
properly translated complete and adjustments are requirements are identified changes effected on a
on a global basis
into practice accurate automated and accurate and fulfilled locally timely basis
• Who are the people involved in process – are they the optimum people; do they understand their part
in the process?
• Do those involved have clearly defined roles and responsibilities?
• How are training and legislative updates handled?
People • Are key responsibilities understood and allocated to the right people?
• How frequently would the business like the calculation/true-up process to be run in an ideal situation
(as part of each month end close / quarterly / bi-annually / annually)?
Process • Where should the different elements of the end-to-end process be run (usually Finance/Tax/Business
split)?
• What controls should be in place to counter key risks? How are the controls going to be monitored?
Technology
• What technology is used currently to support the people and processes?
• How suitable is that for the complexity and / or risks of transfer pricing within the business?
• Have all technology options been considered given the significant advances in recent years?
• What level of automation is optimum for the business?
People: Clear definition of Roles & Responsibilities
Implementation
TP Policy Monitoring Documentation
process
Tax
Board Finance
• TP policy design
• TP documentation
• TP policy defence
• Implementation
• Data gathering
IT • Monitoring Business
• Identifying changes of facts
Adjustments need to
Update of Statutory reflected in statutory
budgets results financials so results
correspond to the TP
policy
Processes– Monitoring
12
TP policy: implementation & monitoring on SAP
1 • Budget input
During the budget exercise, OPEX, sales
Budgeting solution
e.g. SAP BPC
and cost of sales quantities and prices
Pricing setup will be loaded in the system by the
SAP SD business teams
20
Solution Framework- The Building Blocks
Economic analysis and initial
documentation Operational Transfer Pricing
Analytics and
Strategic objective monitoring
setting 1. Process • Validation of policy
operation
• Value-added analytics
and insight
Policy determination
People
2. Organisation Supply Other
Tax Finance Legal Treasury IT
Chain Board, IA
Stakeholders
Reporting
• Country by country
Policy documentation reporting
• Tax return information
• Internal stakeholders
• Audit defence
approach
Local Files
• Process / workflow
Local mgmt. info, org chart,
• Feedback and update
intra-group payments,
financial data for arms
length calcs., APAs Workflow
Deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member
firms in more than 150 countries and territories, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most
complex business challenges. Deloitte’s more than 200,000 professionals are committed to becoming the standard of excellence.
This communication is for internal distribution and use only among personnel of Deloitte Touche Tohmatsu Limited, its member firms, and their related entities (collectively, the
“Deloitte Network“). None of the Deloitte Network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.
Maison de L’automobile
15 December 2015
Dries Bertrand – Senior Manager - Deloitte Belgium
Alexander Baert – Attorney-at-law - Laga
1
Contents
Introduction
How does this impact your GTM systems & tools / Transformation – what?
Conclusion
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 2
Introduction of
Union Customs
Code
Transformation –
why?
3
From CCC to MCC to……UCC
• Community Customs Code (CCC) and its Implementing Provisions (CCCIP)
• Regulation 2913/1992
• Regulation 2454/1993
• Entry into force 1 May 2016 and full implementation, using all
simplifications and IT applications by the end of 2020
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 4
Aim of the UCC
Facilitation of legitimate trade UCC will modernize
customs and is the
Reinforced need to ensure security and safety new framework on
the rules and
Paperless environment for customs & trade procedures for
customs throughout
Harmonized & standardized application of customs controls
the EU
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 5
General overview of potential impact of the UCC
Authorized
Economic
Operator
Simplifications &
Classification
IT environment
UNION
CUSTOMS CODE
Customs
Origin
Regimes
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 6
UCC Projects Timeline
Target date of S1 S2 S1 S2 S1 S2 S1 S2
UCC Projects related to electronic systems
deployment 2017 2017 2018 2018 2019 2019 2020 2020
1. UCC Registered Exporter System (REX) 01.01.2017
2. UCC Binding Tariff Information System (BTI) Update - Phase 1 01.03.2017
Staged 2. UCC Binding Tariff Information System (BTI) Update - Phase 2 01.10.2018
3. UCC Customs Decisions 02.10.2017
approach of 4. Direct trader access to European Information Systems
02.10.2017
(Uniform user management & digital signature)
implementing IT 5. UCC Proof of Union Status (PoUS) 02.10.2017
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 7
© 2015 Deloitte. Private and confidential.
How does this
impact your GTM
systems & tools
Transformation –
what?
8
Example of potential impact of the UCC
3. Origin (BOI)
EUROPEAN UNION/SWITZERLAND
USA
India
6. Customs
Debt
I E
M X
8. Simplifications and IT
systems
2. Classification (BTI)
5. Customs Clearance
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 9
Customs & Global Trade IT processes
CGT processes need to mapped, put in SOPS and build into technology. The complexity with customs & global trade
processes is the ‘real time’ transactional match between financial data and logistics data where content constantly
needs to be up to date. Economic operators lack such environment and have no or limited governance models in place
GTM technology
ERP
Customs/VAT/Stati
(SAP ECC6) Master Data*
Feeder Conversion
Authorities
stical…
provider
Systems
• Sales and Distribution
• Materials
Management
Trans. Data
• Logistics Execution Master
• … Data
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 10
Global trade master data – UCC impact
Master Data Management
Export Control
Product Exchange Preferential Codes License Rules
Vendors values Rates Status (ECCN/ECN/
ITAR)
ERP
ERP/Global Trade
SPL List
Global Trade
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 11
Global trade functionalities – UCC impact
Regulatory Customs Special Preference Other trade
management management regimes management compliance
Import License
Screening
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 12
The Four Keystones of CGT management
Technology Data Management
• Restricted party screening • Master data management
• Embargo screening • Data quality management
• End-use screening • Global trade content
• Anti-boycott screening • Restricted parties/entities
• Classification management • Embargo lists
• License management • Classification data
• Free Trade Agreements management • Systems role definitions
• Import/Export filing • Data tagging
• Trade document generation • Data access policy management
• Broker integration Technology Data
• Metrics and reporting
Management
• Records retention
• Metrics and reporting
• Workflow and rules
Processes
People &
&
Organization
Procedures
Processes & Procedures People & Organization
• Service provider management • Leadership and commitment
• Customs filing • Policies definition and management
• Applying for licenses • Culture of awareness
• License reporting • Global regulatory knowledge
• Agreements reporting • Regional regulatory knowledge
• Mergers and acquisitions advisory • Technical regulatory knowledge
• End-use research and assurance management • Systems and tools proficiency
• Anti-boycott research and assurance • Cross functional collaboration
management
• Training
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 13
Transform today for
the challenges of
tomorrow
Transformation –
how?
14
Summary – Points of attention
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 15
What do you need to do?
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 16
Way forward
OPPORTUNITY AWARENESS
SPOTTING / &TRAINING
RISK
MITIGATION
UCC
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 17
Thank you
Q&A
Fernand Rutten, Partner, Customs & Global Trade, Global lead, +32 2 600 66 06 or frutten@deloitte.com
Dries Bertrand, Customs & Global Trade, Senior Manager, +32 2 600 66 76, dbertrand@deloitte.com
Alexander Baert, Attorney-at-law, Laga, +32 2 800 71 51 or abaert@laga.be
D. Bertrand & A. Baert - The new Union Customs Code requires new system changes - TMC Conference - 24 November 2015 18
Transform today
for the challenges
of tomorrow
Centralized VAT
compliance
1
Contents
• Components of Compliance
• Executing on strategy
In Deloitte’s 2014 indirect tax client
survey, our clients identified indirect tax
compliance as their number 1 priority
area.
Only 30% of respondents to our global
compliance survey were happy that their
centralised compliance processes were
efficient.
The current landscape
4
Pressures on indirect tax teams
Increasing
scope of
‘indirect’
taxes
VAT is a big number Behaviour-based penalty regimes
Operating model
Outsourcing model Decentralized Coordinated, consolidated Centralized, Integrated
Degree of functional
integration Little sharing Co-location Full integration
Prepared by separate local Tax and statutory accounts Shared service team prepares tax
Tax and statutory country teams processes aligned returns and statutory accounts
accounts
With ad-hoc use of advisors on Co-ordinated global outsource Local support for quality
country by country basis working with SSC assurance and specialist input
The push to
centralization
7
Market research - Compliance focus
Current global compliance drivers for organisations and their management
(% Happy)
21% 7% 5%
14%
Specific issues…
• Lack of control; • Lack of control; • Lack of control; • Lack of control;
monitoring; monitoring; monitoring; monitoring;
management management management management
• Complications of • Lack of • Less focus on • Lack of
local knowledge communication these areas communication
from external from external
• No central strategy • Problems with data
partners partners
collection/
• Lack of skills/ integration • No central strategy
expertise
• Lack of skills/
expertise
Market research - Key messages
12
The components of centralising compliance
Centralisation of compliance
Local expertise
The right mix of people
People
People
An multi-disciplinary team comprising:
Combination of
Practical “problem solving”
Strong Tax technical knowledge
experience
Supported by
Continuous professional training
Regular updates of knowledge databases
Periodical
output
Updated tax Information EMEA Tax matrix and Innovative EMEA Tax
Periodical Newsletters
per country overviews tools
Reliable processes
Processes
Processes
• Important to recognise what
‘compliance’ encompasses
• The systems for managing the tax process, KPI data and document
management are becoming ‘standard’ in many Tax functions, but adoption and
approach vary from group to group.
The SMART example
18
© 2014 Deloitte LLP. All rights reserved.
Why SMART?
Centralized approach to compliance
Deloitte centralized approach to Pan European compliance… …leading to challenges
Global
operating
+ models
200 CLIENTS 160 +EMPLOYEES
Limited
30 are large outsourcing accounts Including people of16 different standardization
covering Europe and the globe nationalities Variance in data Numerous data
& automation, sources
quality
higher risks, and
ISAE 3402 lack of control
43,000 certified
+
INDIRECT TAX RETURNS PER YEAR (former SAS 70)
Data integrity
© 2015 Deloitte
What is SMART?
End-to-end Indirect Tax Compliance Solution
SMART is an application developed by Deloitte that bridges the gap between
companies’ ERP systems and their global indirect tax reporting obligations.
Legacy
ERP Systems ITX Listings
returns Reports
Flat files
DWH
• Flexible set-up
• Data cleansing and consolidation
• 35+ Quality checks
• Ready-to-file ITX returns
• Full audit trail
• Standard management reporting
© 2015 Deloitte
Executing the strategy
21
© 2014 Deloitte LLP. All rights reserved.
Executing your strategy
Identify your key stakeholders and determine how to work with them
Take stock of what technology solutions are already available in the GBS and
across your tax groups: you may have more to play with than you expect
Focus on complementing and improving current processes
rather than disrupting them
Deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member
firms in more than 150 countries and territories, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most
complex business challenges. Deloitte’s more than 200,000 professionals are committed to becoming the standard of excellence.
This communication is for internal distribution and use only among personnel of Deloitte Touche Tohmatsu Limited, its member firms, and their related entities (collectively, the
“Deloitte Network“). None of the Deloitte Network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.
1
Contents
1. Introduction
5. Conclusion
1. Introduction
3
1. Introduction
New stakeholders in the tax landscape The perception of tax avoidance has
become a reputational risk
Customers
/ Suppliers
Media /
Volatile NGO’s /
economic Lobbyists
environment
Share
holders /
Boardroom
Increased
Technology
complexity of
challenges
legislation
Tax & Legal CFO / Tax
Risk Dir / Staff
Management
OECD /
BEPS
Globalized More vigilant
business tax
models authorities
EU / Anti-
abuse
National
tax
authorities 4
2. Global tax reset
5
2. Global tax reset
BEPS Actions Related to Transfer Pricing
Action Plan
G20 leaders meet delivered to G20 Finance Ministers
Late 2013
November 2012 Feb 2013 July 2013
Early 2014
7
2. Global tax reset
Example of Unilateral Measures
Anti-hybrid rules introduced and proposals are discussed in the digital area
Announced reform of the corporate tax system to align on international tax law
Legislation on the double Irish Tax structure applicable since 1/1/15 with a 6-
year transitional arrangement.
BEFORE AFTER
CbC Reporting
© 2015 Deloitte Belgium 9
2. Global tax reset
Action 13: timing 1st CbC reporting
Next steps
• Adoption of new documentation requirements in domestic legislations;
• Creation of a centralized exchange platform for tax authorities;
• Formal signing ceremony of MCAA (January 2016).
• 2020 ?
10
2. Global tax reset
Action 13: Country-by-Country reporting implementation package
Transfer Pricing adjustments imposed by country tax administration shall not be based on CBC
reports: “Country by Country report on its own does not constitute conclusive evidence that
transfer pricings are or are not appropriate”
11
2. Global tax reset
Current view on CbC implementation
Already implemented /
Implementation in progress
Expected to implement
Hard to predict
Further to the release of final report on Action 13, the three-tier documentation package is designed to be implemented via
changes in domestic law by the end of 2016. 12
3. What are the
new requirements?
13
3. What are the new requirements?
BEPS-driven structure of transfer pricing documentation
• Any Constituent shall notify the tax authority of its tax residence
country whether it is the Ultimate Parent Entity or Surrogate Parent
Notification Entity who files the CBC Report
obligation • If the Constituent is not the Ultimate Parent or Surrogate UP, it shall
report the identification and address of the UP or SUP.
16
3. What are the new requirements?
Content CbC reporting
1 Overview of allocation of income, tax and
business activities by tax jurisdiction
17
3. What are the new requirements?
1. Overview of allocation of income, tax and business
activities by tax jurisdiction
18
3. What are the new requirements?
2. List of constituent legal entities and business activities by
tax jurisdiction
19
3. What are the new requirements?
Allocation of income, tax & business activities
Balances
Stated Capital
Overview of allocation of income, B/S Cumulated Earnings
1 tax and business activities by tax
jurisdiction Tangible Assets(*)
HR Data
Transaction
21
4. How to get prepared?
Different operating possibilities
23
4. How to get prepared ?
Identifying & extracting the right financial data source
Point of attentions
• Multiple ERP or
no ERP
CDX+
Technological Maturity
• No dual GAAP
capabilities in
system or not
maintained /
used currently
• No uniform
Statutory
Accounts
CDX Process /
System (Excel
based
adjustments)
Functional Capabilities
26
CbC first experiences
Taxpayer: case 2
Ratio 1 – Accumulated earnings vs Assets
As one can observe, CbC reporting eases the identification of tax / profit
discrepancies among Group (per country) from a high-level perspective.
© 2015 Deloitte Belgium
28
CbC first experiences
Taxpayer: case 2
Ratio 1 – Profit before tax vs Employees
29
4. How to get prepared ?
Technology: Deloitte CDX / CDX+ - Live Demo
CDX+: Audit Trail to Financial Systems - IFRS to Stat Rec - TP Ratios
30
5. Conclusion
31
5. Conclusion
Key considerations to address in a CBC discussion
Risk Management
What/Where are the Group “material” legal entities?
Opportunity
What else can be done with “CbC-like” data?
25
5. Conclusion
CbC readiness requires
33
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee (“DTTL”), its network of member firms, and their related entities.
DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as “Deloitte Global”) does not provide services to clients. Please see
www.deloitte.com/about for a more detailed description of DTTL and its member firms.
Deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member
firms in more than 150 countries and territories, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most
complex business challenges. Deloitte’s more than 200,000 professionals are committed to becoming the standard of excellence.
This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the “Deloitte
Network”) is, by means of this communication, rendering professional advice or services. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained
by any person who relies on this communication.
Maison de L’automobile
15 December 2015
Rainer Eismayr – Director, Deloitte Germany
Pieter Van Dyck – Manager, Deloitte Belgium
1
Contents
3
E-Data requirements
Common IT & ERP Landscape
Financial systems Tax compliance and assurance system Reporting
and fillings
Extract
Main ERP Tax desktop
Analysis,
Analysis, Reporting
Tax data warehouse
Transform
ERP
calculation,
calculation, and fillings
adjustments
adjustments
Legacy
General ledger
data Tax forms
Income
L1 L2
Transactions Tax software
data store Adjustments
data
Load
II. Tax
Determination
IFRS
Transfer
Pricing Cross border reporting
SAF-T
SAF-T: General
• General ledger
Periodically per legal entity • Accounts payable
• Accounts receivable
• Fixed assets
Master data
• Inventory
Trans-
action Several audit domains:
• VAT
Balances
• CIT
• Transfer pricing
• …
eAudit across
Europe
8
eAudit across Europe
Priority 1 countries
Germany
Luxembourg
Poland (mid 2016)
France
Hungary (2016)
Portugal
Priority 1
9
eAudit across Europe
Priority 2 & 3 countries
Priority 2
Priority 3
Medium
Low
• Austria • Czech Rep
• Bulgaria
• Belgium • Denmark
• Cyprus
• Finland • Netherlands
• Greece
• Ireland • Norway
• Italy
• Spain • Slovenia
• Latvia
• UK • Sweden
• Lithuania
• Switzerland
• Malta
• Romania
eAudit across Europe
Different levels of complexity & likelihood
High
France Germany
Luxembourg
• Exemptions for FSI
• SAF-T Lite
Low
Less data Complexity More data
Our approach &
typical
challenges
12
Our approach
Technology Organisatio
n
Analyze Extract Complement Reconcile Format Explain Archive
> Review Extract the tax Add relevant Reconcile tax Format Tax Prepare Store tax
significant relevant data working eAudit file eAudit File explanatory eAudit Files,
Business from the ERP documents: with working according to notes Supporting
event for the system. documents local regarding the Documents &
period > GAAP to requirements various data Explanatory
Tax relevant Stat sets (eAudit notes on a
> Review data depends conversion file File, working CD/DVD/Hard
Accounting on the documents,..) drive
systems jurisdiction > VAT
landscape computation
• What data?
Data Extraction • How to extract it?
• What about complex IT infrastructure?
• …
14
eAudit in
Germany
15
eAudit in Germany
Introduction
The rules governing the powers of the tax authorities are set out in detail in the German
Principles of electronic archiving of accounting and tax information, Data Access and the
Auditability of Digital Records (“GoBD”).
These rules define 3 levels of data access
• Direct (Z1)
• Indirect (Z2)
• eAudit file (Z3)
The eAudit file needs to contain all tax relevant data. German tax legislation does not provide
formal specifications regarding form & content of the tax eAudit data file.
eAudit in Germany
Most commonly resquested data
DATA TYPE DATA DEFINITION EXAMPLES OF DATA FIELDS
Master Data GL Account GL Account Number, GL Account Description and GL account class
Master Data Customer Master Customer ID, Customer Name, Customer Country and Customer VAT Number
Master Data Vendor Master Vendor ID, Vendor Name, Vendor Country and Vendor VAT number
Master Data Tax Code Tax Code ID and Tax Code description
Master Data Journal Category Journal Code, Journal Label (Invoice, Payment, FA, Manual)
Balances GL Account Balance Fiscal Year, GL Account Number, Opening balance, Total Debit, Total Credit, Ending Balance,..
Balances Customer Balance Fiscal Year, Customer ID, Customer Opening Balance, Customer Ending Balance
Balances Vendor Balance Fiscal Year, Vendor ID, Vendor Opening Balance, Vendor Ending Balance
Fiscal Year, Fiscal Period, Journal Code, Journal Name, Journal Date, GL account Number,
Transactions GL Journals
Journal Description
Fiscal Year, Invoice Number, Invoice Date, Invoice Gross amount, Invoice Tax, Amount,
Transactions Invoices/Credit Notes
Vendor/Customer ID, Tax Code
Transactions Payments Fiscal Year, Payment Number, Payment Date, Payment Amount, Vendor/Customer ID
17
eAudit in Germany
Risks & Penalties for non compliance
Penalties up to 250.000 EUR in case:
• Electronic bookkeeping maintained abroad without prior authorization
• Data access not provided to tax auditor within a reasonable timeframe
Bookkeeping not kept in accordance with German tax Law can lead to:
• Ex-officio assessment (Estimation of German tax base)
• Electronic bookkeeping (Server) to be relocated (back) to Germany
• GL bookkeeping process of German Tax Payer to be relocated (back) to Germany
18
eAudit in Germany – Periodic data mining
Tools & Auditing method used by tax authorities
19
eAudit in Germany – Periodic data mining
Tools used by the German tax authorities
Example: Tax officer looking for non-deductible expenses for tax purposes
• AIS Tax Audit: query to detect non-deductible expenses like donations, penalties or
presents which are not accounted correctly
• Following steps are carried out by the tax officer:
1. Mapping of the relevant fields
2. Determination of filters (e.g.: GL accounts, keywords)
3. Preparation of a file including the relevant accounting lines
4. Preparation of a documentation regarding the findings
eAudit in Germany – Periodic data mining
Example / best practices
A. Mapping of the relevant fields Mapping
Required ERP
data fields tables as
to uploaded
perform into the
the test software
macro by the tax
auditor
eAudit in Germany – Periodic data mining
Example / best practices
B. Determination of filters (eg GL accounts, keywords)
• Limitation of GL accounts to be scanned
• Determination of keywords included in the posting text eg “Hotel”, “Gift”
Enter search
terms
Input range
of accounts
to perform
the test on
eAudit in Germany – Periodic data mining
Example / best practices
C&D. Non- deductible expenses – result & documentation
Print report
Test-macro result
eAudit in Germany – Periodic data mining
Example / best practices
C&D. Non- deductible expenses – • All validation routines in the software
result & documentation can be performed
by the tax auditor in one batch, i.e.
• Direct display findings with regard to
very low effort with a
the non-deductible expenses
high statistical likelihood to find errors
> all expenses are booked correctly /
leading to additional
incorrectly
tax assessments at the end of the tax
• Tax auditor can prepare a audit
documentation regarding
his / her findings during the audit
eAudit in Germany
Case study
Situation: • 2013: the former ERP system was
changed to SAP ERP 6.0. The data
• Multinational US headquartered
has been archived electronically by
group in the biopharmaceutical
the IT department without consulting
industry had a tax audit ongoing
the tax / accounting department
(income tax and VAT) for the years
2008 – 2011 • The tax auditor request:
• The accounting was done in a • a direct access to the ERP system
Shared Service center in Poland but of the German subsidiaries for the
the German tax authorities were not years under audit (Z1 access)
informed prior to relocating the
• alternatively an electronic audit file
accounting to Poland
for tax for each entity and year
eAudit in Germany
Case study
Issue:
An analysis revealed that the former system could not be restored. A review of the
electronic data files showed that the data was not in line with the German financial
statements as the US-GAAP to German GAAP bridge was missing in the data
files.
Tax auditor threatened to estimate the taxable profits which would have led to
additional income taxes of approx. € 5mio.
eAudit in Germany
Case study
Outcome:
Client had to
• Go through a full restructuring exercise of the electronic raw data to prepare the
data in accordance with the financial statements in order to avoid an estimation
of the tax base and a relocation of the accounting back to Germany
• Draft new eAudit files for all years under audit
Recommendation:
Prepare the electronic audit files each year together with the filing of the tax return
in order to avoid issues with the tax authorities in a later tax audit.
eAudit in France
28
© 2014 Deloitte LLP. All rights reserved.
eAudit in France
Introduction
eAudit Legislation into force since A transactional French GAAP tax eAudit
01/01/2014 for all years open for audit file (FEC - Fichier d’Ecritures
Comptables) must be submitted to the
The eAudit legislation is applicable on:
French tax administration (FTA) at the
• Legal entities beginning of the tax audit.
34
© 2014 Deloitte LLP. All rights reserved.
eAudit & your organisation
Conclusion
• Policy review • Data sources
• Process manuals • Data collection
• Training • Data limitations
• Roles and • Audit trail
responsibilities • Legacy systems
• Large volumes
• Local adjustments
• Extraction programs • Reconciliations
• Assembly & storage • Extraction – storage
• ERP localizations
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee (“DTTL”), its network of member firms, and their related entities.
DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as “Deloitte Global”) does not provide services to clients. Please see
www.deloitte.com/about for a more detailed description of DTTL and its member firms.
Deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member
firms in more than 150 countries and territories, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most
complex business challenges. Deloitte’s more than 200,000 professionals are committed to becoming the standard of excellence.
This communication is for internal distribution and use only among personnel of Deloitte Touche Tohmatsu Limited, its member firms, and their related entities (collectively, the
“Deloitte Network“). None of the Deloitte Network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.
1
Contents
1. Introduction
2. Sales invoices
3. Purchase invoices
5. Conclusions
REPORTING
CHANGE MANAGEMENT
VAT reporting should be
Make a proper case study and
possible in an easy manner,
make sure everybody is on ANALYTICS avoiding human intervention.
board when automating.
Set up in such way that invoices
can be easily checked in an
© 2015 Deloitte Belgium
automated way
Sales invoices
The importance of the lay out of your • Ideally contain intrastat info – if needed
invoices is often underestimated. • Is customer using OCR?
An invoice needs to be • You may not know but a lot of
• Clear at first glance companies do nowadays
• Interpretation is per se not OK • Then your invoice lay out matters
• VAT compliant at minimum (e.g. templates, standard ERP lay
outs)
• Extra fields like a ship from are very
useful • Is a document that your customer
receives and needs to work with.
• Internally
• And for the customer
Typically all parameters are known to have a tax code determined automatically by the
system.
E.g. BE BE 1 1 A1
E.g. BE BE 2 1 A0
E.g. BE AT 1 1 A2
Standard tax code determination is made more and more intelligent through
• Extra parameters
• Use of specific tax code determination software such as bolt ons, also for EU.
E.g. BE BE 1 1 EXW A1
E.g. BE BE 1 1 FCA A0
E.g. BE AT 1 1 DAP A2
© 2015 Deloitte Belgium
Sales invoices – tax code determination
Typical pitfalls
• Limited determination
• Only core business manual invoicing goes wrong
• Transport conditions are not taken into account
• Specifics are set up but the users are not aware of it, do not understand what has been
set up
• Lack of documentation
• Lack of training
• Users are not sufficiently informed about the possibilities
• Knowing what the system does or does not do, can prevent issues.
© 2015 Deloitte Belgium
Sales invoices – electronic invoicing
• The use of an electronic signature shall be ‒ Legibility of the invoice has been added
subject to the acceptance of the recipient ‒ From issue until the end of storage
‒ Consent is still required. period
• To avoid that people receive electronic • Definitions
invoices which they are not able to ‒ Authenticity of origin = Assurance of the
treat due to IT technical restrictions identity of the supplier or issuer
• The need to guarantee authenticity of of the invoice
the origin and integrity of the contents ‒ Integrity of contents = Contents has not
remains mandatory been altered
‒ Now applies to both paper and
electronic invoices
Each taxable person shall determine the way to ensure the authenticity
and integrity
• By business controls
• Which create a reliable audit trail between an invoice and a supply of goods and services
− Supply chain documents such as PO, delivery notes, payment
− Three-way matching principle
• Technological means can still be used.
• EDI
• Qualified electronic signature created by means of a SSCD
• By 31 December 2016 an assessment report will be made.
© 2015 Deloitte Belgium
Sales invoices – storage
13
Purchase invoices
How to deal with purchase invoices in an efficient and VAT compliant manner?
Things to consider:
• Each invoice you receive needs to get posted and a tax code needs to be assigned
tax code determination
Technology Organisation
• Each invoice you receive needs to be entered in your accounting
ideally in an automated way. E.g. via e-invoicing
But also have a solution in place to deal with paper invoices efficiently.
• Self-billing avoids that you have to enter the invoice in your accounting
can be done in an automated way.
Re-trigger
Tax Function the tax Auto-Tax
Module function
module
The VAT rules that apply to e-invoices for Purchase invoices are
the same as for Sales invoices (see above).
Some key considerations:
• PDF invoices received via e-mail can be opened in an automated
way (e.g. e-mail connector) and processed by means of OCR.
• A portal (PO flip over) makes invoices easier to post/process in your
ERP system.
• In order to keep only the scanned images, specific requirements need to be met, which
are country dependent.
‒ E.g. France does not allow digital archiving of paper invoices received
‒ E.g. Belgium allows scanning under specific requirements
• A new circular letter is to be expected for Belgium
• Place where invoices are sent to for processing. Is it allowed to send invoices abroad?
Year end discounts – Belgian specifics that customer can raise a self-bill
© 2015 Deloitte Belgium
Other relevant
documents
20
Other relevant documents
Your company will receive other documents than invoices which will have a VAT
impact:
• Expense note
• Digital expense notes
• VAT refund claims
• Customs documents
• Import & Export declarations
Legislation is slowly
catching up with
1
innovation. Also
Should your company inspections will
wait to automate
invoice processes to
get e.g. more legal
certainty?
No, surely not.
A lot can be done
3 be done in a
different way.
Be prepared
for it.
A well
managed
2
already in a VAT
compliant way.
Reflection and
documentation is
key.
4 invoice
process
will
prevent
errors/risk
Questions
We are happy to
answer any question
you might have.
Tank you for
attending our break
out session.
Deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member
firms in more than 150 countries and territories, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most
complex business challenges. Deloitte’s more than 200,000 professionals are committed to becoming the standard of excellence.
This communication is for internal distribution and use only among personnel of Deloitte Touche Tohmatsu Limited, its member firms, and their related entities (collectively, the
“Deloitte Network“). None of the Deloitte Network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.
Maison de L’automobile
15 December 2015
1
Contents
How to deal with the tax transformation - Need for a structured approach
3
Tax Department is a large consumer of data
Several types of tax relevant data
Financial
• Most statutory • Master file / Local file • Trial balances • GAAP adjustments
accounts • VAT ledger • e-Tax returns &
• Paper tax returns • Expense reports e-Audit
• Tax calculations • Forecasts • Share options
• Tax payments • Tax adjustments
Unstructured Structured
• Valuation reports • APAs* • Employee numbers • Business activities
• DTA* recognition • Master file / Local file and locations • Due dates
• Tax advice • UTPs* • Tax registrations • Work allocations
• R&D timesheets
Non-Financial
*DTA – Deferred tax asset
*APA – Advance pricing agreement
*UTP – Uncertain tax position
© 2015 Deloitte Belgium 4
Complexity of Tax Technology Landscape
Fragmented origination & processing of tax
relevant data
Regulatory and • Changing • Ethics and accountability issues • Korea requires disclosure of
Tax Control Framework.
social change regulations, • Tax administration relationships
specifically in EU • Stakeholder focus • China requires access to
internal tax risk control
systems.
Transparency • Increased scrutiny of • Transparency about operational targets and • Australia assigned risk ratings
to large enterprises.
and risk fiscal behaviour degree of control
management • Rules about tax • Defined responsibilities and upheld through • India is having more audit-
processes supervision based controls.
• Tax risks in business’ internal processes • UK requires a Senior
• New legislation (national and international) Accounting Officer.
for management, supervisors and financial
• The Netherlands implemented
authorities (e.g., the AFM, the Netherlands Horizontal Monitoring.
Authority for the Financial Markets)
• Germany requires standard
audit file for tax e-audit.
8
Tax department objective
Transform to become more efficient in Operator
role and enable Strategist and Ambassador role
10
Structured approach needed
Framework: Key components of tax
transformation
Global direct tax
Global indirect tax
Accounting for tax (provision) People
and
organization
Process
Cash tax and payment management
and policy
Close, provision, and process
Regulatory compliance
Technology
and systems
Data and
information
Enablers
Value drivers
2 options
Outsource provider
teams
• Local offices
• Compliance centres
• Centres of excellence
• Service centres
• A mix of resources
• Onshore
• Nearshore
• Farshore
Dashboard DataFlow /
FileRoom WorkFlow Reporting Calendar Data Management
• Web-based document • Task and due • Tax portal or • Manage Tax • Standardize
management & date management desktop, including Deadlines collection of
storage visibility into KPI’s supplemental tax
• Auto notifications • Publish and track
• Document indexing to Tax Dept data
• Proactively external and
for quick search members of internal due dates • Consolidate data
monitor status of
• Control access to assigned tasks workflow, from data collects
• Available “Out-of and integrate with
documents and • Integrate process calendar, and data –the-box” global
manage versions control steps and collection tax workpapers or
content tax systems
sign-offs activities
18
People and Organisation
Transformation impacts Tax Practitioners
20
Tax Transformation Roadmap
Guiding principles for step by step approach
Workstream May Jun Jul Oct Jan Apr Jul Oct Jan
2015 2015 2015 2015 2016 2016 2016 2016 2017
Source data
Automation
ONESOURCE
Tax Provision
ONESOURCE
Return to
Provision
ONESOURCE
Workflow
Manager
Case study – Sample Roadmap
Strategic observations
• Review data sources for each phase of the tax life cycle and document
the data providers and requests within a workflow tool
26
Tax Transformation journey
Wrap-up
- Data and Technology cause challenges for Tax
departments: landscape is complex and
1 - Significant focus on operational matters
- External trends further accentuate those
challenges
Regulatory compliance
Enablers
This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively,
the “Deloitte Network”) is, by means of this communication, rendering professional advice or services. No entity in the Deloitte network shall be responsible for
any loss whatsoever sustained by any person who relies on this communication.
2
Setting the scene
• Is your company involved in import or export activities?
What
Specific flows require a specific treatment companies
think they are
doing, is quite
often different
3rd Parties are doing the actual filing
from what they
are “doing”
Are we impacted
VAT
by export
deferral? …
controls?
CGT Analytics: tools and sources
4
3
Other tools and support
2
1 GTM Dashboard
Declaration data
11
Setting the scene
• Are your ‘VAT’ and ‘intrastat’ master data under control?
• Do you know which invoices are the most important ones to check in terms of
amounts?
Setting the scene
Consistent
Impact of VAT
Incoterms? Actual flows treatments Services for
applied? invoices issued
to established
entities?
How many ERP Missing CN
systems do you codes
have
How many different VAT numbers?
Questions
We are happy to
answer any question
you might have.
Thank you for
attending our break
out session.
Deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member
firms in more than 150 countries and territories, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most
complex business challenges. Deloitte’s more than 200,000 professionals are committed to becoming the standard of excellence.
This communication is for internal distribution and use only among personnel of Deloitte Touche Tohmatsu Limited, its member firms, and their related entities (collectively, the
“Deloitte Network“). None of the Deloitte Network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.
Maison de L’automobile
15 December 2015
Gino Van Hoornyck - Deloitte Belgium
Chris Kinders – Deloitte Netherlands
1
Contents
• Technology
SSC strategy
Organisation Role of retained finance
Tax and local GAAP knowledge at SSC
5
Statutory accounting and corporate tax reporting
Why integrate these processes?
• Harmonized E2E compliance process
• Integrated workflow management
Process Efficiency
• Simplify data management
• Reduce lead-time & efforts
Consulted Responsible
Informed Informed
RFO SSCs
• Confirm availabilities • Provide source data • Provide additional data • Clarify/confirm ad hoc • Review and approve • Submit CIT return and
• Calendar of internal due • Prior year package • Business information matters statutory financial
dates update statements (where
Company • Share business info client is required to do
update so)
• Assess impact of non- • Discuss impact of non- • Prepare draft CIT • Finalize CIT return • Submit CIT return and
routine business events routine business events returns • Prepare Deloitte statutory financial
on stat & tax on tax compliance • Review book-to-tax standard Tax Reporting • Review and discuss statements (where
Deloitte compliance reporting reporting reconciliations (RTA) Memo client comments Deloitte is able to do
Local so)
• Assess impact of non- • Perform data validation • Discuss impact of non- • Prepare local GAAP TB • Finalize statutory • Review and discuss • Post return and • Data analytics
routine business events • Monitor data gathering routine business events (GAAP conversion) financial statements client comments deliverables to DTi • Regional / global
on stat & tax process on tax compliance • Prep book-to-tax • Review Tax Reporting reporting on tax issues
Global Tax compliance reporting • Inform client of reporting reconciliations (RTA) Memo for consistency
• Review due dates and additional information • Monitor timely requests • Prepare statutory checks
Center agree calendar needs and receipt of data from financial statements
• Governance and the regional vantage
process point
Supporting
Technology
Deloitte Tax Insight
Statutory accounting and corporate tax reporting
Mapping Roles and Responsibilities
Statutory accounting and corporate tax reporting
A new resourcing model
Historic resourcing Future resourcing
model model
Process
Technology Knowledge
New skillset:
People are knowledge workers • Accounting and Finance • Technology
• Tax technical • Communication
• Business • Mobility
Technology
13
Technology - Deloitte Tax Insight
DTi, our web-based collaboration solution that supports efficiency, transparency and
enhanced performance. This secure web-based “digital dashboard” provides access to our
collaboration space, allowing us to share information with our clients 24 hours a day.
Key Benefits
• Achieve greater visibility
• One source of truth
• Improved control
Technology - Deloitte Conversion Tool (DCT)
Replacing previous Excel based Conversion files, The Deloitte Conversion Tool (DCT) is an
application developed by Deloitte to support GAAP to GAAP reconciliation and provide
companies with multiple reporting functionalities.
Key Benefits
• Reduce risk
• Achieve greater visibility
• Save time
• Ensure standardization
• Improve consistency
• Minimizes on going
report maintenance
How to get started – Q&A
?
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee (“DTTL”), its network of member firms, and their related entities.
DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as “Deloitte Global”) does not provide services to clients. Please see
www.deloitte.com/about for a more detailed description of DTTL and its member firms.
Deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member
firms in more than 150 countries and territories, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most
complex business challenges. Deloitte’s more than 200,000 professionals are committed to becoming the standard of excellence.
This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the “Deloitte
Network”) is, by means of this communication, rendering professional advice or services. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained
by any person who relies on this communication.
Maison de L’automobile
15 December 2015
Andre Claes – Partner, Deloitte Belgium
Mark Kennedy – Partner, Deloitte UK
Patrick Joucken – Partner, Deloitte Belgium
1
Management of tax
The environment
3
Management of tax
The business response
Tax
Tax Data Governance
and and Risk
Systems Management
Tax Operating
Resourcing
Models 4
Tax Resourcing Models
Components/building blocks of the tax function
More likely in SSC More likely in Tax
Operational Strategic
7
Tax Manager Objectives
Moving from Operator to Strategist – Current state
Ambassador Strategist
3% Stakeholder management 1% Planning
9%
Reporting
10% 40%
Review Information
Gathering
15%
Rework
22%
Tax
Adjustments
8
Rating scale:
Questions 1 – I have not started yet
Where do you stand? 5 – We are ready!
9
Rating scale:
Questions 1 – I have not started yet
Where do you stand? 5 – We are ready!
10
Rating scale:
Questions 1 – I have not started yet
Where do you stand? 5 – We are ready!
3. Are tax roles and responsibilities well defined between finance and the tax
department?
11
Rating scale:
Questions 1 – I have not started yet
Where do you stand? 5 – We are ready!
12
Rating scale:
Questions 1 – I have not started yet
Where do you stand? 5 – We are ready!
5. Are the VAT ledgers produced by a system and require little or no adjustments?
13
Rating scale:
Questions 1 – I have not started yet
Where do you stand? 5 – We are ready!
14
Rating scale:
Questions 1 – I have not started yet
Where do you stand? 5 – We are ready!
15
Rating scale:
Questions 1 – I have not started yet
Where do you stand? 5 – We are ready!
16
Tax Manager Objectives
Moving from Operator to Strategist – Future state
10%
Information
Gathering
25% 10%
Planning Tax
Adjustments
10%
Rework
10%
25% Review
Stakeholders
Management
10%
Reporting
17
“We always overestimate the change that will occur in the
next 2 years and underestimate the change that will occur in
the next 10. Don’t let yourself be lulled into inaction”
- Bill Gates
18
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee (“DTTL”), its network of member firms, and their related entities.
DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as “Deloitte Global”) does not provide services to clients. Please see
www.deloitte.com/about for a more detailed description of DTTL and its member firms.
Deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member
firms in more than 150 countries and territories, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most
complex business challenges. Deloitte’s more than 200,000 professionals are committed to becoming the standard of excellence.
This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the “Deloitte
Network”) is, by means of this communication, rendering professional advice or services. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained
by any person who relies on this communication.