Major tax challenges for the financial sector

Major tax challenges for the financial sector

On October 6-7 we held our annual Nordic tax conference for the financial sector.

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Partner / Head of Financial Services, Tax

KPMG i Sverige

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The KPMG Nordic FS Tax Conference is a joint event hosted by KPMG in Sweden, Denmark, Norway and Finland and this year it was held in Stockholm. KPMG representatives and approximately 70 clients from all of the Nordic region, as well as Iceland, met for two days of discussions regarding the rapidly changing, and increasingly complex environment for companies within the financial sector.


We were especially honored to be able to introduce Jane McCormick, the KPMG Global Head of Tax, as the opening speaker. Jane spoke on the topic of “the state of play of FS in tax” and touched on, among other areas, the increased requirements for transparency and sustainability, BEPS, the growing compliance-burden, and implications of Brexit.


After that it was time to welcome Lars Hammarsten, Head of Group Operational Taxes at the Swedish bank Swedbank, and Jennifer Sponzilli of KPMG UK, on the theme of knowing your client (KYC= and reporting requirements). It was fascinating to gain insight into the day-to-day workings of a bank and of how to manage the growing list of regulatory requirements. It became especially apparent that the KYC process is a significant big challenge for Swedish banks and can involve everything from finding emigrated small account-holders to managing the bigger issues associated with the regulatory implementation.


Day two started with a run-through of the Norwegian proposal to implement a financial tax on business that operate financial activities, which had been announced only the previous day. Karin Remoe, Group Head of Tax Planning at Gjensidige Forsikring, questioned exactly what type of “financial tax” it really is and precisely what the scope of the legislation will be.


Pontus Fornell, FS Tax Director KPMG Sweden
– Karin’s presentation was very interesting and it appeared that the legislation process in Norway has been fast tracked as the proposal is intended to enter into force from the 1st January 2017. It will be exciting to monitor how the Norwegian tax will be applied in practice. We are currently monitoring how the Swedish proposal on a financial activity tax, which is due to be presented on November 7, is going to be formulated. We look forward to presenting the Swedish proposal at KPMG’s Tax Day (Stora Skattedag) on November 9.


Antti Leppänen, Tax Partner KPMG Finland

– I talked about the new PE definition in light of BEPS. This matters as the new definition, when adopted, the new PE definition will cause a number of interpretative questions. Also, it can be expected that PE:s will be created for the financial companies more often on the basis of the dependent agent concept when an agent plays the principal role leading to the conclusion of contracts on behalf of the financial company. These are interesting times and we look forward to welcoming everyone to Finland for the conference in 2017!


Nils Schmid, FS Tax Partner KPMG Sweden

– The conference clarified that this is a very complex period from a regulatory point of view, with many comprehensive initiatives from the OECD, EU etc., which will especially affect the financial sector. In order to keep up with the avalanche of different reporting requirements which have come into force, or are on their way, like FATCA, CRS and CbC; its high time for the companies to evaluate their resources and to ensure that they can handle these requirements. Furthermore, one has to take into account that companies’ tax policies will be reviewed by both the tax authorities and the general public to a greater extent, and therefore there is a need to develop tax strategies which will work for the tax system of tomorrow. Next up it will be exciting to view the Swedish Tax Agency’s presentation to the Government on its project regarding tax policy issues. Our expectation is that the Swedish Tax Agency’s proposal will be presented on Monday, October 31.


Furthermore, I would like to elevate the in-depth talks we held with focus on the tax-related developments in the following topics:

  • Regulatory change – an overview of regulatory developments and their potential impact on tax 
  • Increased focus on tax avoidance; real, perceived or non-existent –broader discussions with examples. 
  • Is your input VAT recoverable? Overview of latest developments in partial exemption for financial institutions
  • VAT developments in the financial industry including cost sharing, Skandia and ATP-case (C 464/12)
  • PE definition in light of BEPS. Proposals, trends & developments and the Nordic experience
  • Investment management; latest developments on withholding taxes and EU law related issues
  • Attribution of profits; latest developments and practice from the Nordics
  • Reorganizations and restructurings; recent tax related developments


These are examples of topics which should be taken into account when working with taxes in the financial sector. You are welcome to contact us should you like to know more about everything pertaining to tax and the financial sector. And welcome to Finland 2017!

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