Engaging with High Net Worth Individuals on Tax Compliance

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High Net Worth Individuals (HNWIs) pose significant challenges to tax administrations due to the complexity of their affairs, their revenue contribution, the opportunity for aggressive tax planning, and the impact of their compliance behaviour on the integrity of the tax system.  This publication examines in detail this taxpayer segment, describes their usage of aggressive tax planning schemes and proposes prevention, detection and response strategies that tax administrations can use to respond to these challenges. It also addresses aspects of voluntary disclosure initiatives for past non-compliance that may be particularly pertinent in the current environment.

The publication outlines a number of innovative approaches to enable governments to better manage the risks involved with marketed tax schemes and tailor-made arrangements.  To improve compliance, tax administrations could consider changing the structure of their operations to focus resources effectively, for example, through the creation of a dedicated HNWI unit. Other recommendations include creating the appropriate legal framework, exploring forms of co-operative compliance and engaging more in international co-operation, at both the strategic and operational level.



Voluntary disclosure regarding past non-compliance

Over the past few months the international tax environment has changed dramatically towards greater transparency and exchange of information for tax purposes. All financial centres1 have now committed to the OECD standard on transparency and exchange of information2. Austria, Belgium, Luxembourg and Switzerland have withdrawn their reservation to Article 26 of the OECD Model Tax Convention. Countries are now moving towards implementation of these standards as emphasised by the leaders of the G20 at the London Summit on 2 April 2009. The OECD has issued a report which shows the progress in implementation. An ever larger number of tax information exchange agreements are being signed. Progress is also being made in updating treaty networks to the OECD standard and some countries are bringing in domestic law mechanisms that permit exchange of information for tax purposes.3 Tax administrations are active in promoting new tools which will provide them with more information, such as the United States Qualified Intermediary programme.4 The European Union is discussing the extension of its Savings Directive to investments not currently covered. In response to the current financial and economic crisis governments are taking increasingly robust measures to counter international tax evasion and those who assist in facilitating it.


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