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  • Cyber security merger and acquisition trends: PwC
    room Facts and figures Press contacts Analyst relations Global International PwC Sites Commonly visited PwC sites Global Australia Brazil Canada China Hong Kong France Germany India Italy Japan Mexico Middle East Netherlands Russia Singapore South Africa South Korea Spain Sweden Switzerland United Kingdom United States Complete list of PwC territory sites Cyber Security M A Decoding deals in the global Cyber Security industry Download Global Cyber Security spending is expected to reach 60 billion in 2011 and is forecast to grow at 10 percent every year during the next three to five years The U S accounts for more than half of all deals globally triggered by growing cyber threats and increasing awareness among both organizations and consumers of accelerating breaches and attacks from our report Total deal activity since 2008 has exceeded 22 billion globally In the first half of 2011 there were 37 deals accounting for over 10 billion in deal value representing a 70 percent increase compared to full year 2010 Since 2008 the total investment in global Cyber Security deals has exceeded 22 billion an average of over 6 billion in each year In most regions the private sector accounts for the majority of Cyber Security spending while the U S is the notable exception where government spending is almost equal to the private sector The strong U S technology industry combined with the fact that the U S defense and intelligence budgets are significantly larger than in any other country are key market drivers Other key drivers underpinning growth in Cyber Security spending include Increasing cyber threats both from new actors and new threat vectors the paths that attacks can take Greater vulnerabilities due to the more pervasive use of technology particularly mobile devices and cloud computing Increasing awareness by organizations and consumers of the

    Original URL path: http://www.pwc.com/gx/en/industries/aerospace-defence/publications/cyber-security-mergers-and-acquisitions.html (2016-02-10)
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  • Innovate to gain technological advantage in aerospace & defence: PwC
    Our contribution to the debate Genesis Park Diversity and inclusion Analyst relations Alumni Member firms worldwide Live events and discussions Strategy Research insights View featured Browse by issue Browse by industry Browse by service Monthly highlights Spotlight The CEO agenda CEO insights blog Careers About PwC Technology careers Employer of choice Our history PwC Professional Employability Aspire to lead PwC s series on leadership and gender equality Country job search Explore careers with Strategy Press room Facts and figures Press contacts Analyst relations Global International PwC Sites Commonly visited PwC sites Global Australia Brazil Canada China Hong Kong France Germany India Italy Japan Mexico Middle East Netherlands Russia Singapore South Africa South Korea Spain Sweden Switzerland United Kingdom United States Complete list of PwC territory sites A D Insights Gaining technological advantage The Aerospace Defence A D Industry Group has launched our second edition of A D Insights Gaining technological advantage Why talk about gaining technological advantage It s really all about getting and keeping market share in your markets old and new Differentiation has long been critical to gaining and maintaining contracts programme positioning and market share It s even more important today given the increasing globalisation of the industry The A D industry has been the source of some of the most influential technological advances in modern history computers and computer networking satellites and satellite navigation and important advances in physics all have their roots in the sector s research That s why it should come as no surprise to anyone that we at PwC believe there is a strong innovation imperative for the industry The executives we interviewed agree PwC recently conducted a series of interviews with 18 CEOs and senior executives in the industry on the subject of new technologies and adjacent markets They told us

    Original URL path: http://www.pwc.com/gx/en/industries/aerospace-defence/publications/aerospace-defence-insights-gaining-technological-advantage.html (2016-02-10)
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  • ETF 2020: Preparing for a new horizon: Asset Management: PwC
    Italy Japan Mexico Middle East Netherlands Russia Singapore South Africa South Korea Spain Sweden Switzerland United Kingdom United States Complete list of PwC territory sites Exchange traded funds ETFs Understanding the future opportunities and challenges PwC s Nigel Brashaw talks about the developments of the ETF industry globally and in the US PwC s Andy O Callaghan and Marie Coady discuss the future of the ETF industry in Europe PwC s Maria Tsui talks about ETF in Asia a young expanding industry with many local variations 1 2 3 Download The ETF Exchange Traded Fund market is growing at a rapid pace Growing far beyond their initial function of tracking large liquid indices in developed markets ETFs now hold over 2 6 trillion of assets globally ETFs are no longer a niche product and their impact will continue to be felt much more widely than imagined As such all financial services firms should consider developing an ETF strategy In this report we have surveyed asset managers service providers and other industry participants around the world in an effort to better understand regional developments in ETFs and use their expertise as a sounding board for our own perspectives ETF 2020 Preparing for a new Horizon leverages the results of our global survey and our insights to paint a picture of how the ETF business and landscape is likely to develop globally over the next six years To help asset managers prepare to compete in this fast changing environment we have considered the ongoing evolution barriers to growth and the opportunities that lie ahead and how they can plan for 2020 AUM today Our research shows that 78 of firms see AUM today of 2 6trn growing to at least 5trn by 2020 Share Asset management Hedge funds Insight Meet our team

    Original URL path: http://www.pwc.com/gx/en/industries/financial-services/asset-management/publications/etf-2020.html (2016-02-10)
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  • Asia’s new fund passports pose tax questions: PwC
    Cooperation APEC Asia Region Funds Passport ARFP the Association of Southeast Asian Nations ASEAN Collective Investment Scheme CIS and the Mainland Hong Kong Mutual Recognition of Funds agreement Asia Region Funds Passport The Asian Region Funds Passport ARFP is planned to start in 2016 In September 2015 the finance ministers of Australia Japan Korea New Zealand the Philippines and Thailand signed a statement of understanding confirming their commitment to join A draft Memorandum of Understanding setting out the passport s framework should be finalised in 2015 It is anticipated that eligible APEC economies would implement the ARFP in local legislation within the following 12 months There is a strong feeling that unless the tax aspects are addressed the passport will not succeed There are a number of key tax principles which should be incorporated in the ARFP to achieve tax neutrality Create a level playing field regarding investor returns Remove tax barriers impeding crossborder distribution Preserve tax neutrality through collective investment schemes Preserve integrity by mitigating tax evasion The questions that will need to be addressed at each level are The investor level How is the investor taxed if investing in a foreign fund versus a local fund Are there any withholding taxes that apply Are there any concessions that apply to local investors versus foreign investors Are there any integrity measures that apply The fund level Is there any tax at the fund level How is the fund taxed on its local investments versus foreign investments Do the tax attributes of the investment flow to investors ie transparent treatment of funds Under the current taxing regimes for each participating economy there are some significant differences in investors tax outcomes Without doubt tax outcomes influence investors choice of investment products So to what extent can anti discrimination measures make sure that the viability and competitiveness of funds from participating economies are not adversely affected Careful consideration of such measures will need to be undertaken which may include Passport funds are not subject to tax No withholding tax on distributions from the passport fund and distributions from investee companies Passport funds are exempted from capital gains on the disposal of investee companies Participating countries are required to adopt the the Organisation for Economic Co operation and Development OECD Common Reporting Standard or other integrity measures ASEAN CIS The ASEAN CIS is now a year old and has shown a slow but promising start Its participating countries are Singapore Malaysia and Thailand A few regionally dominant asset management houses have launched schemes which are in various regulatory approval stages in the three participating countries The tax issues are similar to those affecting the ARFP Hong Kong China Mutual Recognition of Funds MRF scheme After more than two years of speculation the MRF was implemented on 1 July 2015 laying a foundation for greater integration of the Asian asset management industry The MRF opens up the Chinese retail and institutional investors huge savings pool to Hong Kong and international asset managers In return

    Original URL path: http://www.pwc.com/gx/en/industries/financial-services/asset-management/publications/asset-management-insights/asia-new-fund-passports-pose-tax-questions.html (2016-02-10)
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  • Transforming your business for a new global tax world: PwC
    world As asset management companies grow in influence tax will become a key differentiator While the asset management industry will grow rapidly in the coming years growth for individual firms will not be automatic Tax in particular will be a key operational and business activity requiring specialist resources a new approach and integration into front and middle office activities including data reporting product development distribution and brand strategy Tax and reputation will be inseparable concepts Taxes will now be viewed as an operational risk joining the ranks of other key risks which senior management takes a keen interest in and one that needs a strategically planned risk management programme integrated into all aspects of their business operations How a firm deals with tax risk will be viewed as a competitive advantage or disadvantage In 2020 and beyond investors expectations will include a robust and efficient tax infrastructure And zero tolerance of tax uncertainty or tax adjustments In addition as many countries struggle with deficit reduction and the need to invest the whole of the financial services industry including asset management will be expected to play its part in policing the global financial system and ensuring that the tax authorities have the correct tax information on taxpayers Total transparency of investor residency and identity will be the norm Asset managers will have to demonstrate the highest standards of anti money laundering and know your customer responsibilities plus reporting to tax authorities and to taxpayers on the returns flowing from their funds Politicians regulators the media and the public will all expect nothing less But tax should not be considered solely as a risk to manage it is also an opportunity Managing tax risks and leakages well at all levels investments funds and investors can distinguish asset managers from their peers While managers have traditionally been tasked with generating performance alpha for their investors service alpha in 2020 will be a key differentiator The concept of service alpha implies an entirely new challenge for asset managers how to communicate with investors about tax matters Service alpha requires the asset manager to first explain it and then help investors recognise its benefits These issues are addressed by our new report Asset Management 2020 and beyond Transforming your business for a new global tax world It anticipates portfolio taxation becoming a key battleground tax branding moving to the heart of marketing and reputation and tax technology becoming essential for improving the function s performance Our report envisages the tax function of the future becoming a trusted adviser within the business with highly skilled tax people being moved to the heart of the business and the tax function receiving information in a tax ready format Tax functions will rely on professional data analysis tools to help decision making and will devote considerable resources to data security In short the role of the tax function will change emphatically Its priority will be to provide assurance that asset management firms their funds and their investors are paying

    Original URL path: http://www.pwc.com/gx/en/industries/financial-services/asset-management/publications/asset-management-insights/transforming-your-business-for-a-new-global-tax-world.html (2016-02-10)
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  • OECD releases documents for country-by-country reporting: PwC
    three model competent authority agreements that could be used by each country depending on whether it intends to effect exchange of CbCRs through the Multilateral Convention on Mutual Administrative Assistance in Tax Matters the exchange of information article of a bilateral tax convention or a bilateral tax information exchange agreement Neither the model legislation nor any of the model competent authority agreements contains additional guidance regarding the particular data that multinational enterprises MNEs need to provide in the CbCRs Rather the model legislation merely sets forth a general description of that data and suggests that it should be provided in a form identical to and applying the definitions and instructions contained in the standard template set out either in the OECD Transfer Pricing Guidelines the final report on BEPS Action 13 or an appendix to the legislation once adopted Presumably the standard template referred to can be expected to look like the CbCR template set forth in the OECD s first report on Action 13 released on 16 September 2014 In this regard however the introduction to the implementation package indicates that as a next step an XML Schema and related User Guide will be developed with a view to accommodating the electronic exchange of the CbCRs Additional guidance on the CbCR data requirements may emerge once this schema and user guide are issued Helpfully the model legislation and model competent authority agreements also reveal the OECD members current thinking on among other things how a MNE group is to be comprised for purposes of the filing requirements which small MNE groups would be excluded from the requirements which entity in the MNE group would be expected to file the CbCR and the intended government use and confidentiality of the CbCR information The takeaway Key takeaways are that the CbC reporting obligation will fall on the ultimate parent entity If however the ultimate parent is not obligated to file or the jurisdiction of the ultimate parent does not have an exchange of information agreement in place or there has been a systematic failure under that agreement then the MNE group may appoint a surrogate parent entity to do the filing in its country of tax residence Furthermore if in the above scenarios the MNE group does not appoint a surrogate then each constituent entity will have to file the CbCR locally The implementation package contains measures meant to address concerns of MNE groups regarding the lack of rigorous safeguards for the commercially sensitive information to be shared among tax authorities under the proposed CbC reporting requirements Specifically a country s tax administration shall preserve the confidentiality of the information contained in the country by country report at least to the same extent that would apply if such information were provided to it under the provisions of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters Whether and how countries can actually implement and police these use and confidentiality restrictions of course remains to be seen As the OECD has

    Original URL path: http://www.pwc.com/gx/en/industries/financial-services/asset-management/publications/asset-management-insights/oecd-releases-documents-for-country-by-country-reporting.html (2016-02-10)
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  • BEPS for alternative investment funds: PwC
    before making the required reporting to the various tax administrations AIFs should also continue to assess current structures and activities and be prepared to manage increased transparency demands for information on beneficial owners and intangibles increased global audit risk and potential changes to transfer pricing methodologies operations and investment structures Final recommendations on treaty abuse and multilateral instruments The recommendations on treaty abuse will make it more difficult for AIFs to gain access to certain countries tax treaties in the future The OECD has focused on the tax treaty entitlement of different types of organisations over the course of the BEPS project The final recommendations on treaty abuse do not specifically recommend any treatment for CIVs and their eligibility for benefits under a treaty s limitation on benefits LOB provision Instead it surmises that countries during their bilateral negotiations can choose to include CIVs in the definition of qualifying persons in the LOB provision LOB provisions generally prohibit third country residents from obtaining treaty benefits For example a foreign corporation may not be entitled to a reduced rate of withholding unless a minimum percentage of its owners are citizens or residents of the treaty country The OECD also recommended that a pension fund should be considered to be a resident of the jurisdiction in which it is organised regardless of whether it benefits from a tax exemption in that jurisdiction As the recommendations are currently drafted a pension fund will be regarded as a qualifying person of a jurisdiction only when at least 50 of all pensioners are resident in either contracting jurisdiction The OECD has proposed relaxing this requirement by also including pension funds when more than 90 of the beneficiaries are individuals resident in a contracting jurisdiction or another jurisdiction where they are entitled to treaty benefits and the pension fund itself would be entitled to the same or lower dividend and interest withholding tax if that pension fund would have been a resident of the other jurisdiction The OECD seeks participation from all member states on the development and negotiation of a multilateral instrument which would serve to modify bilateral tax treaties with over 80 countries participating as of 5 October 2015 As part of the final proposal the OECD has proposed three approaches that countries can follow to prevent tax treaty shopping and abuse These include a limitation on benefits LOB rule and principal purpose test PPT PPT only or LOB plus anti conduit mechanism Further work on entitlement of non CIV funds and treaty benefits will continue in 2016 Concerns remain regarding how pension funds should be taken into account and treated for the purposes of applying treaty benefits under a multilateral instrument This was highlighted by a submission to the OECD by a coalition of global pension funds Next steps Evaluate where you currently rely on treaty benefits AIFs should review the substance surrounding their current treaty structures and determine whether additional substance is required to continue relying on current benefits As treaty benefits have come under increased scrutiny the interest among the industry has increased in alternative investment structures such as securitisation regimes and real estate investment trust REIT structures that qualify for preferential tax treatment in their country While these structures may be more costly to set up and maintain this cost may be outweighed by the increased certainty that these structures will be eligible for beneficial tax treatment today and in the future AIFs should analyse whether treaty structures will stand up to scrutiny the impact if treaty benefits were to be denied and the feasibility of utilising alternative investment structures in the future Final recommendations on hybrids and interest deductibility The recommendations on hybrid instruments and interest deductibility will require tracking interest expense and income inclusion when a hybrid arrangement is in place The report focuses on the importance of coordination between countries in the implementation and application of the hybrid mismatch rules to ensure that the rules are effective An example of a hybrid mismatch arrangement is one in which there is a deduction in one country with no corresponding income inclusion in the recipient country The OECD is recommending rules that would deny a deduction to the payor under a hybrid mismatch arrangement to the extent the payment is not included in the income of the recipient The OECD recommends that if a deduction is granted to the payor the recipient should be required to include the payment in its ordinary income Payments could be affected by these rules even when a hybrid does not result in deferral or a change in character The OECD s recommendations address so called excessive interest and other financial payments The OECD has identified two potential general rules with work on further application guidance on these rules continuing into 2016 The primary rule is a fixed ratio test that would restrict interest expense based on net interest over EBITDA Countries will be able to set the ratio between 10 and 30 If the primary rule is exceeded a higher interest deduction may be available in certain circumstances if the interest burden is higher at a group level This is called the group ratio rule Some discretion has been suggested for countries to include implementing one or a combination of these rules which may have a direct bearing on the acceptable capital structure or allowable interest deductions for investment vehicles Next steps Evaluate current hybrid arrangements AIFs should evaluate current hybrid arrangements and understand whether the countries in which they operate are contemplating anti hybrid legislation As a result of the OECD recommendations AIVs will potentially need to restructure existing arrangements to manage tax expense within their funds or corporate groups Further important opportunities remain regarding the use of supportable debt financing for AIF structures while these are still available they also are subjected to increased scrutiny and review by tax authorities given the increased discussion regarding the level and pricing of financial transactions Detailed work around the pricing of financial transactions remains

    Original URL path: http://www.pwc.com/gx/en/industries/financial-services/asset-management/publications/asset-management-insights/beps-for-alternative-investment-funds.html (2016-02-10)
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  • Europe's increasingly complex tax reporting: PwC
    as an additional distribution in the hands of the investors holding shares at the end of the relevant accounting period It is deemed to have been received six months after the end of the accounting period As investors will use this information when completing their tax returns accurate and timely reporting of the relevant information is paramount from an investor relations perspective Germany Why Tax reporting obligations for foreign funds are regulated by the German Investment Act in German referred to as Investmentsteurgesetz or InvStG Under the InvStG a fund can be transparent or non transparent for German tax purposes For German investors only the transparent fund provides the highest tax efficiency How Various reporting requirements need to be fulfilled in order for a German investor to obtain the maximum tax optimisation from offshore funds including annual reporting and daily NAV frequency based tax reporting The InvStG also imposes a compulsory daily publication of the ADDI Accumulated Deemed Distributed Income To benefit from certain tax advantages in Germany the InvStG also requires the publication of Zwischengewinn Interim Profit Aktiengewinn I II Equity Profit I II and Immobiliengewinn Real Estate Profit The accuracy of this information is key for German investors not only to ensure a smooth tax declaration process but also to avoid dormant tax risks Austria Why From an Austrian tax perspective investment funds are considered transparent requiring a direct allocation of funds income to their investors Austrian investors are therefore subject to annual taxation regardless of whether the income of the fund is distributed or accumulated How Accumulated income also referred to as deemed distributed income DDI has to be calculated and electronically filed by an Austrian tax representative Switzerland Why Swiss private investors have to declare their taxable income and the value of the investment in their tax return Therefore it is recommended that information is made available to Swiss private investors to protect them from prohibitive income taxation It is necessary to ascertain the taxable income in order to separate it from tax exempt capital gains in the hands of Swiss private investors based on Swiss calculation principles How In Switzerland no specific deadline for calculating the income tax value applies However generally we recommend publishing income tax values by April May of the year following the fiscal year end of the entities as Swiss private investors generally start preparing their tax returns at that time For the purposes of income tax and personal wealth tax the respective taxable income and net asset value per share can be provided to the Swiss Federal Tax Administration FTA The FTA then publishes the above values in the official rates list Please note the FTA will only publish share classes that have a Swiss Valoren number Italy Why Since 1 July 2014 profits from certain Collective Investment Funds and SICAVs hereinafter funds have been generally subject to a 26 final taxation in lieu of the previous 12 5 tax rate Profits deriving from direct investment in eligible bonds i

    Original URL path: http://www.pwc.com/gx/en/industries/financial-services/asset-management/publications/asset-management-insights/europe-increasingly-complex-tax-reporting.html (2016-02-10)
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