Do uncertain tax positions as disclosed in your financial accounts under IFRS or US GAAP create reportable transactions under DAC – 6 and vice-versa?
Both accounting standards and DAC – 6 are putting disclosure requirements on taxpayers for perceived “aggressive” tax arrangements, however the background and rational of these rules differ. Under DAC – 6, tax authorities for more transparency around very specifically defined (ie, Hallmarks) transactions whereas the accounting standard board wants to ensure that all (tax) risks are accounted for to avoid misleading investors and other relevant stakeholders.
Given these different goals pursued, the disclosures under each system are different and thus miss-alignment is programmed. Under DAC -6 specific transactions are targeted for disclosure to tax authorities, whereas accounting standards capture every tax related risk and require disclosure to all stakeholders.
With this objective in mind, we invite you to an informative webinar where we will discuss the following:
• An overview of how the tax treatments (positions) are made under IFRIC 23 and ASC 740;
• An overview of the mandatory disclosures required to be made under DAC6;
• Discussion on whether an uncertain tax position will lead to a DAC 6 disclosure and examples of such disclosures