A Solution Perspective
An Open Source Collaborative and Foundational
Solution Targeted at Non-OECD Member Countries
February 9, 2016
CONTEXT
SOLUTION CONCEPT
ADDRESSING KEY CBCR REQUIREMENTS
DATA SECURITY
INFORMATION ACCESS IMPLICATIONS
FUNCTIONALTY & ADAPTATION
EXAMPLE INFORMATION FLOW
KEY CAPABILITIES DISCUSSION
2
Context
BEPS Action 13
& Guidance
Multilateral Competent
Authority Agreement
3
Global Forum
Roadmap Findings
Common Transmission
System Tender
Action 13 Requires Confidentiality
4
IT & Staff Challenges
Roadmap Item #1
5
MCAA Relies Upon Questionnaire
6
CTS Focuses on Transmission
7
CONTEXT
SOLUTION CONCEPT
ADDRESSING KEY CBCR REQUIREMENTS
DATA SECURITY
INFORMATION ACCESS IMPLICATIONS
FUNCTIONALTY & ADAPTATION
EXAMPLE INFORMATION FLOW
KEY CAPABILITIES DISCUSSION
2
Solution Concept
An App to TIE it all Together
TIE
TIE
TIE
TIE
TIE
TIE
TIE
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TIE - Tax Information Exchange Application
Secure, Simple, Standardized
Concept is to create an Application to be used for InterGovernmental Tax Information Exchange
• Like a phone handset for a telephone network – point to
point
̶ Specific for tax information exchange (TIE)
̶ Relies upon and Enhances OECD Common Transmission
System
̶ Focused on CbCR information exchange, yet designed to be
adapted to handle many types of information
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CONTEXT
SOLUTION CONCEPT
ADDRESSING KEY CBCR REQUIREMENTS
DATA SECURITY
INFORMATION ACCESS IMPLICATIONS
FUNCTIONALTY & ADAPTATION
EXAMPLE INFORMATION FLOW
KEY CAPABILITIES DISCUSSION
2
Addressing Key CbCR Requirements
High Degree of Alignment with Tax Authority Needs
• 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
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– Integrates training on both the system and the information
contained therein; definitions of CbCR data elements as
disclosed
Addressing Key CbCR Requirements
Benefits for Multinational Corporate Taxpayers
• 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
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CONTEXT
SOLUTION CONCEPT
ADDRESSING KEY CBCR REQUIREMENTS
DATA SECURITY
INFORMATION ACCESS IMPLICATIONS
FUNCTIONALTY & ADAPTATION
EXAMPLE INFORMATION FLOW
KEY CAPABILITIES DISCUSSION
2
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.
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CONTEXT
SOLUTION CONCEPT
ADDRESSING KEY CBCR REQUIREMENTS
DATA SECURITY
INFORMATION ACCESS IMPLICATIONS
FUNCTIONALTY & ADAPTATION
EXAMPLE INFORMATION FLOW
KEY CAPABILITIES DISCUSSION
2
Information Access Implications
Welcome to the TIE Application
Melanie Smith
Send Information
->Create Exchange
->View Status of Exchanges
->Cancel Exchange
Receive Information
->26 New Items
Training Support Reports Administer
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Initial Scope – CbCR Starting Point
CbCR Exchange of Information provides the high value yet
reasonably limited technical scope needed for success
• 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
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CONTEXT
SOLUTION CONCEPT
ADDRESSING KEY CBCR REQUIREMENTS
DATA SECURITY
INFORMATION ACCESS IMPLICATIONS
FUNCTIONALITY & ADAPTATION
EXAMPLE INFORMATION FLOW
KEY CAPABILITIES DISCUSSION
2
TIE Simplifies Access to CTS Functionality
 TIE Relies on Common Transmission System
(CTS) for Message Transmission
• Provides easy way to access CTS functionality
• Enables regional approaches
Includes the following capabilities:
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Organization
Registration &
ID Management
End User
Registration &
Access
Management
Inbound
Transmission
Management
End User
Localized
Training
Message
Storage &
Encryption
System &
Network Event
Management
Outbound
Transmission
Management
Counterparty
Validation
Management
TIE Initial Functionality CbCR Focused
 Support Country-by-Country Report Management
• Basic features
Manage
Reportable
Jurisdictions
Compose CbCR
Message
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Manage
Contacts of
Reportable
Jurisdiction
Encrypt/Decrypt
Message
Manage
Reporting
Multinational
Corporation
Send Message
Accept
Multinational
Corporation
Filing
Manage
Inbound
Message
Archive
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 countryspecific 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. CNN in EU
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Example: TIE Potential Enhanced Functionality
 Common Reporting Standard (CRS)
• Significant features in common
Manage
Reportable
Jurisdictions
Compose CRS
Message
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Manage
Contacts of
Reportable
Jurisdiction
Encrypt/Decrypt
Message
Manage
Reporting
Financial
Institution
Send Message
Request /
Accept
Reportable
Account Info
Manage
Inbound
Message
Archive
TIE Examples: Future Functionality
Supports Expansion from CbCR to other information
exchange and functional needs
•
•
•
•
•
•
•
•
•
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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
CONTEXT
SOLUTION CONCEPT
ADDRESSING KEY CBCR REQUIREMENTS
DATA SECURITY
INFORMATION ACCESS IMPLICATIONS
FUNCTIONALTY & ADAPTATION
EXAMPLE INFORMATION FLOW
KEY CAPABILITIES DISCUSSION
2
TIE Information Flow Example
Credentials and Policies of
Government exchange are managed
by the Competent Authorities w/in TIE
Apps
CbC content in format required by the
headquarter residence authority
CbC Data in Outbound Format,
Encryption and Transmission
Protocol, Currency, Language of
Country A
Company Boundaries
TIE Application
Report Lists Activity in
Countries A,B, C, D, E
CTS
CbC
CbC
Country A
Credentials
CbC
CTS
Translation
Country B
Metrics
Metadata
Credentials
XXX
Transmission
Authorization
Service
CbC
CTS
Country C
CbC
CNN
Identity Service
Country D
Access Control
List/
Treaty and Peer
Review Service
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Country A List
Excludes Country
C
To Country E per Custom
Enhancement
CbC
Country E
Proprietary
CONTEXT
SOLUTION CONCEPT
ADDRESSING KEY CBCR REQUIREMENTS
DATA SECURITY
INFORMATION ACCESS IMPLICATIONS
FUNCTIONALTY & ADAPTATION
EXAMPLE INFORMATION FLOW
KEY CAPABILITIES DISCUSSION
2