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Editorial

In anticipation of the launch of International Tax Review's Financial Services Tax website, the annual publication on Capital Markets tax developments has been repositioned to also cover banking, asset and wealth management, private equity and fund management from a tax perspective.

In Europe, discussion around the financial transaction tax being taken forward by 10 EU member states continues to top the list of concerns for financial services taxpayers, but there is activity on other fronts, too.

The Alternative Investment Fund Managers Directive takes full effect from July 22 and final administrative preparations are being performed. AIFMD compliance is required to obtain a licence to manage or market EU AIFs from 2015, so fine-tuning processes to ensure compliance with it alongside related requirements at national level remains a priority. You will also find out within these pages why uncertainty is reducing the market value of dividends on Swiss stocks.

In the US, there is a continued focus on the Foreign Account Tax Compliance Act (FATCA). A list of participating foreign financial institutions has been published, and intergovernmental agreements continue to be signed, while in the Asia-Pacific region India is unsurprisingly fertile ground on which to find tax controversy. Specific issues are cropping up for foreign banks in the country, as well as for foreign investors.

Bank levies are seen as the favoured tool for legislators seeking to appease the populist view that financial institutions should bear the cost of losses stemming from banking risk, and the fact 16 European countries have implemented one bears this out. Even the business-friendly UK tax regime has seen its bank levy raised successively in recent years. The levy provides great variety and flexibility in scope, so do not be surprised if this trend takes hold elsewhere, too.

For private equity fund investors, the impact of the OECD's multilateral BEPS project is a critical issue. Despite the OECD acknowledging that the position of collective investment vehicles must be addressed, greater elaboration on the specific challenges is required.

Whether it is information regarding worldwide initiatives such as BEPS or FATCA 2.0 – the term being used to describe the global standard of automatic tax information exchange – or domestically-focused updates on Belgian business restructuring or the implications of Mexican tax reform for the financial sector, this publication takes a practical approach to providing everything you need to effectively manage your financial services tax issues

Matthew Gilleard

Corporate tax editor, International Tax Review

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