2019/2020 International Tax Survey

	Not important	Slightly important	Important	Fairly important	Very important
Tax Technology	Tax Technology Not important	Tax Technology Slightly important	Tax Technology Important	Tax Technology Fairly important	Tax Technology Very important
EU Anti-Tax Avoidance Directive	EU Anti-Tax Avoidance Directive Not important	EU Anti-Tax Avoidance Directive Slightly important	EU Anti-Tax Avoidance Directive Important	EU Anti-Tax Avoidance Directive Fairly important	EU Anti-Tax Avoidance Directive Very important
US Tax Reform	US Tax Reform Not important	US Tax Reform Slightly important	US Tax Reform Important	US Tax Reform Fairly important	US Tax Reform Very important
Brexit	Brexit Not important	Brexit Slightly important	Brexit Important	Brexit Fairly important	Brexit Very important
Tax Disputes with the authorities	Tax Disputes with the authorities Not important	Tax Disputes with the authorities Slightly important	Tax Disputes with the authorities Important	Tax Disputes with the authorities Fairly important	Tax Disputes with the authorities Very important
Transfer Pricing Disputes with the authorities	Transfer Pricing Disputes with the authorities Not important	Transfer Pricing Disputes with the authorities Slightly important	Transfer Pricing Disputes with the authorities Important	Transfer Pricing Disputes with the authorities Fairly important	Transfer Pricing Disputes with the authorities Very important
DAC6	DAC6 Not important	DAC6 Slightly important	DAC6 Important	DAC6 Fairly important	DAC6 Very important
Permanent Establishment (PE) issues	Permanent Establishment (PE) issues Not important	Permanent Establishment (PE) issues Slightly important	Permanent Establishment (PE) issues Important	Permanent Establishment (PE) issues Fairly important	Permanent Establishment (PE) issues Very important
Transfer pricing compliance obligations	Transfer pricing compliance obligations Not important	Transfer pricing compliance obligations Slightly important	Transfer pricing compliance obligations Important	Transfer pricing compliance obligations Fairly important	Transfer pricing compliance obligations Very important
Tax Reporting including FIN48 and IFRIC23	Tax Reporting including FIN48 and IFRIC23 Not important	Tax Reporting including FIN48 and IFRIC23 Slightly important	Tax Reporting including FIN48 and IFRIC23 Important	Tax Reporting including FIN48 and IFRIC23 Fairly important	Tax Reporting including FIN48 and IFRIC23 Very important

Not important

Slightly important

Important

Fairly important

Very important

Tax Technology

Tax Technology Not important

Tax Technology Slightly important

Tax Technology Important

Tax Technology Fairly important

Tax Technology Very important

EU Anti-Tax Avoidance Directive

EU Anti-Tax Avoidance Directive Not important

EU Anti-Tax Avoidance Directive Slightly important

EU Anti-Tax Avoidance Directive Important

EU Anti-Tax Avoidance Directive Fairly important

EU Anti-Tax Avoidance Directive Very important

US Tax Reform

US Tax Reform Not important

US Tax Reform Slightly important

US Tax Reform Important

US Tax Reform Fairly important

US Tax Reform Very important

Brexit

Brexit Not important

Brexit Slightly important

Brexit Important

Brexit Fairly important

Brexit Very important

Tax Disputes with the authorities

Tax Disputes with the authorities Not important

Tax Disputes with the authorities Slightly important

Tax Disputes with the authorities Important

Tax Disputes with the authorities Fairly important

Tax Disputes with the authorities Very important

Transfer Pricing Disputes with the authorities

Transfer Pricing Disputes with the authorities Not important

Transfer Pricing Disputes with the authorities Slightly important

Transfer Pricing Disputes with the authorities Important

Transfer Pricing Disputes with the authorities Fairly important

Transfer Pricing Disputes with the authorities Very important

DAC6

DAC6 Not important

DAC6 Slightly important

DAC6 Important

DAC6 Fairly important

DAC6 Very important

Permanent Establishment (PE) issues

Permanent Establishment (PE) issues Not important

Permanent Establishment (PE) issues Slightly important

Permanent Establishment (PE) issues Important

Permanent Establishment (PE) issues Fairly important

Permanent Establishment (PE) issues Very important

Transfer pricing compliance obligations

Transfer pricing compliance obligations Not important

Transfer pricing compliance obligations Slightly important

Transfer pricing compliance obligations Important

Transfer pricing compliance obligations Fairly important

Transfer pricing compliance obligations Very important

Tax Reporting including FIN48 and IFRIC23

Tax Reporting including FIN48 and IFRIC23 Not important

Tax Reporting including FIN48 and IFRIC23 Slightly important

Tax Reporting including FIN48 and IFRIC23 Important

Tax Reporting including FIN48 and IFRIC23 Fairly important

Tax Reporting including FIN48 and IFRIC23 Very important

	Not important	Slightly important	Important	Fairly important	Very important
Controlled foreign company (CFC) rule	Controlled foreign company (CFC) rule Not important	Controlled foreign company (CFC) rule Slightly important	Controlled foreign company (CFC) rule Important	Controlled foreign company (CFC) rule Fairly important	Controlled foreign company (CFC) rule Very important
Hybrid mismatches	Hybrid mismatches Not important	Hybrid mismatches Slightly important	Hybrid mismatches Important	Hybrid mismatches Fairly important	Hybrid mismatches Very important
Switchover rule	Switchover rule Not important	Switchover rule Slightly important	Switchover rule Important	Switchover rule Fairly important	Switchover rule Very important
Exit taxation	Exit taxation Not important	Exit taxation Slightly important	Exit taxation Important	Exit taxation Fairly important	Exit taxation Very important
Interest limitation	Interest limitation Not important	Interest limitation Slightly important	Interest limitation Important	Interest limitation Fairly important	Interest limitation Very important
General anti-abuse rule	General anti-abuse rule Not important	General anti-abuse rule Slightly important	General anti-abuse rule Important	General anti-abuse rule Fairly important	General anti-abuse rule Very important

Not important

Slightly important

Important

Fairly important

Very important

Controlled foreign company (CFC) rule

Controlled foreign company (CFC) rule Not important

Controlled foreign company (CFC) rule Slightly important

Controlled foreign company (CFC) rule Important

Controlled foreign company (CFC) rule Fairly important

Controlled foreign company (CFC) rule Very important

Hybrid mismatches

Hybrid mismatches Not important

Hybrid mismatches Slightly important

Hybrid mismatches Important

Hybrid mismatches Fairly important

Hybrid mismatches Very important

Switchover rule

Switchover rule Not important

Switchover rule Slightly important

Switchover rule Important

Switchover rule Fairly important

Switchover rule Very important

Exit taxation

Exit taxation Not important

Exit taxation Slightly important

Exit taxation Important

Exit taxation Fairly important

Exit taxation Very important

Interest limitation

Interest limitation Not important

Interest limitation Slightly important

Interest limitation Important

Interest limitation Fairly important

Interest limitation Very important

General anti-abuse rule

General anti-abuse rule Not important

General anti-abuse rule Slightly important

General anti-abuse rule Important

General anti-abuse rule Fairly important

General anti-abuse rule Very important

Question Title

* 6. Does your group have a Tax Compliance Management System / Tax Control Framework in place?

A Tax Compliance Management System includes a system of internal controls that assure the accuracy, completeness and timely submission of tax returns, necessary disclosures and any other fiscal obligations by an enterprise. This includes a risk management strategy and system for tax purposes as well

Yes, we run an integrated tax compliance system (integrated with ERP/business systems)

Yes, we have a written code including tax risk and control matrix and processes

No formalised tax compliance system

Currently not, however, we plan to introduce a tax compliance system

Other (please specify)

	Not important	Slightly important	Important	Fairly important	Very important
Pricing of financial transactions (loans, cash pooling, guarantees)	Pricing of financial transactions (loans, cash pooling, guarantees) Not important	Pricing of financial transactions (loans, cash pooling, guarantees) Slightly important	Pricing of financial transactions (loans, cash pooling, guarantees) Important	Pricing of financial transactions (loans, cash pooling, guarantees) Fairly important	Pricing of financial transactions (loans, cash pooling, guarantees) Very important
Pricing of intangibles	Pricing of intangibles Not important	Pricing of intangibles Slightly important	Pricing of intangibles Important	Pricing of intangibles Fairly important	Pricing of intangibles Very important
Delineation of value-adding versus routine functions	Delineation of value-adding versus routine functions Not important	Delineation of value-adding versus routine functions Slightly important	Delineation of value-adding versus routine functions Important	Delineation of value-adding versus routine functions Fairly important	Delineation of value-adding versus routine functions Very important
Intangibles - identification and pricing	Intangibles - identification and pricing Not important	Intangibles - identification and pricing Slightly important	Intangibles - identification and pricing Important	Intangibles - identification and pricing Fairly important	Intangibles - identification and pricing Very important
Availability of benchmarking data	Availability of benchmarking data Not important	Availability of benchmarking data Slightly important	Availability of benchmarking data Important	Availability of benchmarking data Fairly important	Availability of benchmarking data Very important
Monitoring and implementing the TP system	Monitoring and implementing the TP system Not important	Monitoring and implementing the TP system Slightly important	Monitoring and implementing the TP system Important	Monitoring and implementing the TP system Fairly important	Monitoring and implementing the TP system Very important
Preparation of contemporeaneous documentation	Preparation of contemporeaneous documentation Not important	Preparation of contemporeaneous documentation Slightly important	Preparation of contemporeaneous documentation Important	Preparation of contemporeaneous documentation Fairly important	Preparation of contemporeaneous documentation Very important
Risk that tax authorities requalify a transaction (loan-equity, entrepreneur-low risk)	Risk that tax authorities requalify a transaction (loan-equity, entrepreneur-low risk) Not important	Risk that tax authorities requalify a transaction (loan-equity, entrepreneur-low risk) Slightly important	Risk that tax authorities requalify a transaction (loan-equity, entrepreneur-low risk) Important	Risk that tax authorities requalify a transaction (loan-equity, entrepreneur-low risk) Fairly important	Risk that tax authorities requalify a transaction (loan-equity, entrepreneur-low risk) Very important

Not important

Slightly important

Important

Fairly important

Very important

Pricing of financial transactions (loans, cash pooling, guarantees)

Pricing of financial transactions (loans, cash pooling, guarantees) Not important

Pricing of financial transactions (loans, cash pooling, guarantees) Slightly important

Pricing of financial transactions (loans, cash pooling, guarantees) Important

Pricing of financial transactions (loans, cash pooling, guarantees) Fairly important

Pricing of financial transactions (loans, cash pooling, guarantees) Very important

Pricing of intangibles

Pricing of intangibles Not important

Pricing of intangibles Slightly important

Pricing of intangibles Important

Pricing of intangibles Fairly important

Pricing of intangibles Very important

Delineation of value-adding versus routine functions

Delineation of value-adding versus routine functions Not important

Delineation of value-adding versus routine functions Slightly important

Delineation of value-adding versus routine functions Important

Delineation of value-adding versus routine functions Fairly important

Delineation of value-adding versus routine functions Very important

Intangibles - identification and pricing

Intangibles - identification and pricing Not important

Intangibles - identification and pricing Slightly important

Intangibles - identification and pricing Important

Intangibles - identification and pricing Fairly important

Intangibles - identification and pricing Very important

Availability of benchmarking data

Availability of benchmarking data Not important

Availability of benchmarking data Slightly important

Availability of benchmarking data Important

Availability of benchmarking data Fairly important

Availability of benchmarking data Very important

Monitoring and implementing the TP system

Monitoring and implementing the TP system Not important

Monitoring and implementing the TP system Slightly important

Monitoring and implementing the TP system Important

Monitoring and implementing the TP system Fairly important

Monitoring and implementing the TP system Very important

Preparation of contemporeaneous documentation

Preparation of contemporeaneous documentation Not important

Preparation of contemporeaneous documentation Slightly important

Preparation of contemporeaneous documentation Important

Preparation of contemporeaneous documentation Fairly important

Preparation of contemporeaneous documentation Very important

Risk that tax authorities requalify a transaction (loan-equity, entrepreneur-low risk)

Risk that tax authorities requalify a transaction (loan-equity, entrepreneur-low risk) Not important

Risk that tax authorities requalify a transaction (loan-equity, entrepreneur-low risk) Slightly important

Risk that tax authorities requalify a transaction (loan-equity, entrepreneur-low risk) Important

Risk that tax authorities requalify a transaction (loan-equity, entrepreneur-low risk) Fairly important

Risk that tax authorities requalify a transaction (loan-equity, entrepreneur-low risk) Very important

2019/2020 International Tax Survey

In an ever-changing tax world, we want to understand your key concerns.

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* 1. Please enter your territory/Country

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* 2. Please select your industry

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* 3. Please rank the current level of importance for your business for each of the following tax challenges.

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* 4. Please rank the current level of importance for your business for each of the following aspects of the EU Anti-Tax Avoidance Directive

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* 5. Please select which of the following areas your business has recently engaged with the tax authorities within the last 12 months in relation to a Tax and Transfer Pricing enquiry or dispute

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* 7. Please rank the level of importance you foresee in 2020 and beyond for your business for each of the following Transfer Pricing challenges

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* 8. What are the greatest tax challenges your business will foresee in 2020 and beyond?