Monitoring of Tax Risks (MTR)
Switzerland out of Switzerland
We would like to inform you that BRP Tax has updated its Monitoring of Tax Risks for more than 170 jurisdictions actually covered to take into account the evolving tax regulatory legislation relating to private banking clients holding bank accounts abroad:
Onboarding of Structure
– Decision tree to facilitate the specific tax due diligence on structures, considering that:
• Financial intermediaries should investigate, understand, and document the reason and purpose of a domiciliary company when entering into a business relationship with a client or in case of a change in circumstances. FINMA regulations explicitly require institutions to clarify and document the reasons for using a domiciliary company (Art. 9a AMLO-FINMA).
• Further, increased risk criteria should apply in cases of complex structures such as the use of several domiciliary companies or domiciliary companies with fiduciary shareholders, non-transparent jurisdictions as well as cases without a verifiable reason/purpose or short-term asset placement. Appropriate internal directives, policies and instructions, which include the monitoring of transactions, will have to define how the Financial institutions should enter into or continue business relationships with complex structures (Art. 13 al. 2 & Art. 15 AMLO-FINMA).
– The current Key Indicators have been enhanced with new ones:
– List of Tax Haven / Blacklist
– General Anti Avoidance Rules
– MLI Agreement (BEPS)
– Trust / Foundation rules – Transfer pricing rules
– Place of Effective Management rule
– CFC Rules
– EU DAC-6 / MDR rules
Webinar session
– Special webinar sessions will be organized to present the tool with a focus on the new section “Onboarding of Structure”.
If this tool is part of your subscription, you should now be able to access this new version on our Platform: https://mybrponline.com/ once you have logged in under the following search:
| Subscribed MTR Map | Product | Document |
| MTR Map – pdf format MTR Map – csv format | Monitoring Of Tax Risks Monitoring Of Tax Risks | MTR Country Map MTR Country Map CSV |
Please do not hesitate to contact us (info@brptax.com), should you require any further information.
Best regards,
Your BRP Tax Team
Geneva, 16th February 2021