A Solution Perspective
An Open Source Collaborative and Foundational Solution Targeted at Non-OECD Member Countries
February 9, 2016
SOLUTION CONCEPT
INFORMATION ACCESS IMPLICATIONS
ADDRESSING KEY CBCR REQUIREMENTS
KEY CAPABILITIES DISCUSSION
DATA SECURITY
2
EXAMPLE INFORMATION FLOW
CONTEXT
FUNCTIONALTY & ADAPTATION
3
Context
Global Forum Roadmap Findings
Common Transmission System Tender
Multilateral Competent Authority Agreement
BEPS Action 13 & Guidance
4
Action 13 Requires Confidentiality
5
IT & Staff Challenges
Roadmap Item #1
6
MCAA Relies Upon Questionnaire
7
CTS Focuses on Transmission
SOLUTION CONCEPT
INFORMATION ACCESS IMPLICATIONS
ADDRESSING KEY CBCR REQUIREMENTS
KEY CAPABILITIES DISCUSSION
DATA SECURITY
8
EXAMPLE INFORMATION FLOW
CONTEXT
FUNCTIONALTY & ADAPTATION
Solution Concept
9
CTS
TIE
TIE
TIE
TIE
TIE
TIE
TIE
An App to TIE it all Together
10
TIE - Tax Information Exchange Application
Concept is to create an Application to be used for Inter-Governmental Tax Information Exchange • Like a phone handset for a telephone network – point to
point̶? Specific for tax information exchange (TIE)̶? Relies upon and Enhances OECD Common Transmission
System̶? Focused on CbCR information exchange, yet designed to be
adapted to handle many types of information
Secure, Simple, Standardized
SOLUTION CONCEPT
INFORMATION ACCESS IMPLICATIONS
ADDRESSING KEY CBCR REQUIREMENTS
KEY CAPABILITIES DISCUSSION
DATA SECURITY
11
EXAMPLE INFORMATION FLOW
CONTEXT
FUNCTIONALTY & ADAPTATION
12
Addressing Key CbCR Requirements
• Brings simplicity through a high degree of standardization and minimization of technical complexities
• Reduces red tape through unified governance and controls– Simple to implement, simple and secure in use – Enables developing economies to demonstrate compliance with
technical aspects of MCAA/Treaty privacy requirements• Future Proof – designed to be adapted to address other needs• Supports effective use by end users
– Integrates training on both the system and the information contained therein; definitions of CbCR data elements as disclosed
High Degree of Alignment with Tax Authority Needs
13
Addressing Key CbCR Requirements
• Provides security for data once received that matches or exceeds the data security standards referred to in the OECD implementation package and will be dynamic, addressing new security threats as these emerge– Provides confidence essential to building trust
• Promotes a platform upon which Tax Authorities may choose to provide transparency to taxpayers (ie: your data has been received by XXXX country type notifications)
• Enables consistency of understanding across jurisdictions with respect to data as disclosed and described by taxpayer
Benefits for Multinational Corporate Taxpayers
SOLUTION CONCEPT
INFORMATION ACCESS IMPLICATIONS
ADDRESSING KEY CBCR REQUIREMENTS
KEY CAPABILITIES DISCUSSION
DATA SECURITY
14
EXAMPLE INFORMATION FLOW
CONTEXT
FUNCTIONALTY & ADAPTATION
15
Data Security Details
Strong security and access control for received information • Industry standard approach to information security
management (ISO/IEC27000 technical standards)• Data encryption at all layers of technology; storage,
transmission, access• Strong Tax Authority and end user registration and
authentication features• Validation of counterparty right to receive information prior to
transmission (access control lists)• User specific limitations and logging of all actions around data
access, print, download, view, etc.
SOLUTION CONCEPT
INFORMATION ACCESS IMPLICATIONS
ADDRESSING KEY CBCR REQUIREMENTS
KEY CAPABILITIES DISCUSSION
DATA SECURITY
16
EXAMPLE INFORMATION FLOW
CONTEXT
FUNCTIONALTY & ADAPTATION
17
Information Access Implications
Welcome to the TIE Application
Receive Information->26 New Items
Send Information->Create Exchange->View Status of Exchanges->Cancel Exchange
Melanie Smith
Training Support Reports Administer
18
Initial Scope – CbCR Starting Point
• Supports exchange of country-by-country information per OECD spec (no country extensions in first phase)
• Enables automatic exchange (one-to-many) & exchange upon request (one-to-one)
• Support Common Transmission System based messaging
CbCR Exchange of Information provides the high value yet reasonably limited technical scope needed for success
SOLUTION CONCEPT
INFORMATION ACCESS IMPLICATIONS
ADDRESSING KEY CBCR REQUIREMENTS
FUNCTIONALITY & ADAPTATION
KEY CAPABILITIES DISCUSSION
DATA SECURITY
EXAMPLE INFORMATION FLOW
CONTEXT
19
20
TIE Simplifies Access to CTS Functionality
Organization Registration &
ID Management
Outbound TransmissionManagement
End UserRegistration &
Access Management
Inbound Transmission Management
Message Storage & Encryption
System & Network Event Management
TIE Relies on Common Transmission System (CTS) for Message Transmission• Provides easy way to access CTS functionality• Enables regional approaches
CounterpartyValidation
Management
End User Localized Training
Includes the following capabilities:
21
TIE Initial Functionality CbCR Focused
Support Country-by-Country Report Management• Basic features
Manage Reportable
Jurisdictions
Manage Contacts of Reportable Jurisdiction
Manage Reporting
MultinationalCorporation
Accept MultinationalCorporation
Filing
Compose CbCR Message
Encrypt/Decrypt Message Send Message
Manage Inbound Message Archive
22
Adaptable Long Lasting Solution
Designed to be extended to address a variety of tax information exchange needs, current and future• Enhancements based upon by Tax Authority needs; CRS,
TP Comparables, Tax Rulings, ect.• Designed so approved vendors can supply enhancements
in a way that extend functionality or address country-specific needs
• New application modules share consistent security, look and feel and access controls, governance, etc.
• Support for other (regional) messaging gateways could be added over time; eg. CCN in EU
23
Common Reporting Standard (CRS)• Significant features in common
Manage Reportable
Jurisdictions
Manage Contacts of Reportable Jurisdiction
Manage Reporting Financial
Institution
Request / Accept
Reportable Account Info
Compose CRS Message
Encrypt/Decrypt Message Send Message
Manage InboundMessage Archive
Example: TIE Potential Enhanced Functionality
24
TIE Examples: Future Functionality
Supports Expansion from CbCR to other information exchange and functional needs• Country extensions to CbCR data format• Common Reporting Standards• Tax Rulings• Bespoke Information Exchanged upon Request• Beneficial Ownership Information• Tax Treaty Information• Transfer Pricing Arms-length Comparables• Feature: Translation of currency, language• Feature: Analytics and integration with existing data
SOLUTION CONCEPT
INFORMATION ACCESS IMPLICATIONS
ADDRESSING KEY CBCR REQUIREMENTS
FUNCTIONALTY & ADAPTATION
KEY CAPABILITIES DISCUSSION
DATA SECURITY
25
EXAMPLE INFORMATION FLOW
CONTEXT
26
CbC Report Files in Country A
CbC
Company Boundaries
Country A
CbC content in format required by the headquarter residence authority
Report Lists Activity in Countries A,B, C, D, E
27
Exchange of Information Required
CbC
Company Boundaries
Country A
CbC content in format required by the headquarter residence authority
Report Lists Activity in Countries A,B, C, D, E
Country B
Country C
Country D
Country E
28
CTS and Other Formats Needed
CbC
Company Boundaries
Country A
CbC content in format required by the headquarter residence authority
Report Lists Activity in Countries A,B, C, D, E
Country B
Country C
Country D
Country E
CbC CTS
CbC CTS
CbC
CbC CNN
CTS
CbC Proprietary
XXX
29
TIE App Simplifies and Standardizes
CbC
CbC Data in Outbound Format, Encryption and Transmission
Protocol, Currency, Language of Country A
CbC
Company Boundaries
CTS
Translation
CbC CTS
CbC
CbC CNN
CTS
Country B
Country A
Country C
Country D
CbC content in format required by the headquarter residence authority
Country E
CbC Proprietary
To Country E per Custom Enhancement
MetricsMetadata
TIE Application
XXX
Report Lists Activity in Countries A,B, C, D, E
30
Provides Standard Technical Services
CbC
CbC Data in Outbound Format, Encryption and Transmission
Protocol, Currency, Language of Country A
CbC
Company Boundaries
CTS
Translation
CbC CTS
CbC
CbC CNN
CTS
Country B
Country A
Country C
Country D
CbC content in format required by the headquarter residence authority
Country E
CbC Proprietary
To Country E per Custom Enhancement
MetricsMetadata
XXX
Report Lists Activity in Countries A,B, C, D, E
TIE Application
Identity Service
Credentials
Credentials
Credentials and Policies of Government exchange are managed by the Competent Authorities w/in TIE Apps
Transmission Authorization
Service
Access Control List/
Treaty and Peer Review Service
Country A List Excludes Country
C
31
TIE Information Flow Example
Identity Service
CbC
CbC Data in Outbound Format, Encryption and Transmission
Protocol, Currency, Language of Country A
CbC
Credentials
Credentials
Company Boundaries
CTS
Credentials and Policies of Government exchange are managed by the Competent Authorities w/in TIE Apps
Translation
CbC CTS
CbC
CbC CNN
CTS
Country B
Country A
Country C
Transmission Authorization
Service
Access Control List/
Treaty and Peer Review Service
Country A List Excludes Country
C
Country D
CbC content in format required by the headquarter residence authority
Country E
CbC Proprietary
To Country E per Custom Enhancement
MetricsMetadata
TIE Application
XXX
Report Lists Activity in Countries A,B, C, D, E
SOLUTION CONCEPT
INFORMATION ACCESS IMPLICATIONS
ADDRESSING KEY CBCR REQUIREMENTS
KEY CAPABILITIES DISCUSSION
DATA SECURITY
27
EXAMPLE INFORMATION FLOW
CONTEXT
FUNCTIONALTY & ADAPTATION