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cutting through complexity
An overviewJune, 2013
What is the EU FTT?
A proposed tax based on EU law
To be levied by (currently) 11 ‘FTT zone’ EU Member States
On ‘financial transactions’
Involving one FTT-zone party
And one FTT-zone ‘financial institution’
Note: (a) Due to the “Issuance principle” and “residence principle” non-FTT zone parties/financial institutions may also be covered.
The FTT Zone
The EU jurisdictions that are participating in the enhanced cooperation process are:
Other countries may join
Key features (1)
Key features (2)
Draft FTT directive issued (28 Sept 11)
EU Council authorizes FTT for 11 EU Member States (23 Oct 12) under ‘enhanced cooperation’
Revised draft directive issued for 11 EU Member States (14 Feb 13)
EU Commission reviews comment and issues final draft directive
EU Council (11 Member States) to approve final directive
Planned entry into force (1 Jan 14)
Note: (a) there is a general feeling that this timetable is too tight to enable the 11 FTT zone Member States to implement the Directive into their national legislation by 1 January 2014, so there is the possibility that the start will be postponed.
Why is FTT important for the FS sector?
FTT will either have to be absorbed, mitigated or passed on
Product substitution, relocation, etc.
Systems and processes
Will require new or adjusted information, tax collection, payment and reporting systems and processes
FTT exposure (including secondary liability) needs to be identified, mitigated where possible, and residual risk managed
Why is FTT important for the FS sector? (2)
Creates multiple charges
FTT affects every step in chain with only limited exemptions
Unlevel playing field
E.g. FTT zone bank’s non-FTT zone branch at competitive disadvantage with local (non-FTT zone) bank
Will affect non-FTT zone FS businesses
Issuance principle means even non-FTT zone parties will be liable for FTT
Impact not limited to FS
Wide scope means even corporate entities can be liable to FTT (e.g. corporate hedging)
Which businesses may be affected by FTT
KPMGs EU FTT Core Team
KMPG’s FTT resources
EU Core FTT Team
Director, KPMG’s EU Tax Centre
Tel +31 20-656 1485
Hans-Jürgen A. Feyerabend
Partner, Tax FS KPMG In Germany
Tel +49 69 9587 2348
Mobile +49 173 5764050
Senior Manager, Tax FS, Fidal in France
Tel + 33 1 55 68 14 61
Partner, Tax FS, KPMG in the UK
Tel +44 (0) 20 7311 2483
Mobile +44 (0) 7786747242
Partner, Tax FS KStudio Associato in Italy
Tel +39 0267644708
Mobile +39 3483081087
Partner, Tax FS, KPMG in Spain
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