Central and Southeast Europe

Regional Tax Forum 2011

Taxation after the crisis Navigating the coming changes

3rd Special edition

Transfer pricing – always in focus

The trends of tax controversy

2 Special edition Ernst & Young

Foreword Cover: Keystone / Urs Flueeler

Dear Reader

In the ever-changing world of taxation, Ernst & Young is committed to delivering exceptional client service, while remaining at the forefront of tax developments both global and locally. One of the ways we do this is by bringing clients together with Ernst & Young’s most experienced tax professionals to exchange experience and ideas, and provide leading practices for managing the challenges that finance and tax executives face.

For finance and tax executives operating within Central and Southeast Europe, managing multiple countries with very different tax environments can be particularly daunting. To help reduce complexity and provide a better understanding of the issues, Ernst & Young hosts a Regional Tax Forum each year. During this unique event, we cover the most critical global and regional tax issues. We engage in a dialogue that helps promote our understanding of our clients’ most press-ing needs and opens the door for further success through closer collaboration.

This year, we held our 3rd Annual Regional Tax Forum in Warsaw, Poland, dealing specifically with issues relating to Central and Southeast Europe. In response to enthusiastic interest from our clients in previous years, we expanded the range of topics and countries covered. We also allowed more time for interaction and face-to-face meetings. While the ever-popular topics of tax litigation and transfer pricing were on our agenda, we also spent time addressing the challenging new economic environment and shifting fiscal policies, highlighting some of the key driving forces behind recent tax policy changes. With the region containing such a broad range of local tax regimes, we also dealt with the challenges of managing smaller countries with complex systems.

In this special edition, we are proud to present our insights and analysis on some of these pressing topics.

Building success together

Botond Rencz

Jacek Kedzior

The annual Ernst & Young Regional Tax Forum offers a unique opportunity for tax professionals to discuss and exchange ideas on the most important developments related to taxation practices in Central and Southeast

Europe. During this year’s two-day summit held in Warsaw, Poland, a wide range of topics were addressed, including the impact of the new economic environment on fiscal policies, regional and local transfer pricing issues,

indirect tax planning, tax audit trends, findings on global mobility of employees and recent developments in global tax controversy.In-depth analysis from our global network of

Ernst & Young tax professionals further enhanced discussions and also provided excellent grounds for one-to-one meetings between tax professionals and executives from all over Europe.

About the Ernst & Young Regional Tax Forum

Botond RenczInternational Tax Services Leader Central and Southeast Europe Ernst & Young

Jacek KedziorTax and Law Leader Central & Southeast Europe Ernst & Young

Ernst & Young Special edition 3

Fiscal policy

• By Piotr Cizkowicz

The countries of the Central and Southeast European region today

face a number of fiscal policy challenges. A common concern in most countries is the need

for additional public sector financing, due to high deficit levels and rising levels of public debt.

The root cause has been the varying degree of impact resulting from the economic downturn. For example, the Baltic economies contracted more than 10% in 2009, while Poland experienced a more modest slowdown. As the crisis has deepened, a rapid increase in public debt and deficits has been witnessed in almost all countries in the region. In many, public sector debt levels were the highest ever recorded, at over 60%. Although economic performance in the region improved markedly in 2010,

compared with 2009, in most countries there was no visible improvement with regards to overall government balances. Fiscal deficits remained high and have been followed by a further increase in public debt.

Was tax regulation a catalyst of the crisis?Some aspects of tax systems are designed to promote certain types of behavior among both corporations and individuals. As a result, it is possible that certain regulations added to existing financial pressures on companies and households, with the result that they actually contributed to the economic slowdown. For example, mortgage interest rate deductions without a corresponding increase in tax from capital gains, favorable tax treatment of stock option schemes over other types of remuneration, and deductibility of interest payments on debt against corporate income taxes may all have collectively resulted in a

10% In 2010, total financing need (the sum of the government deficit and the stock of maturing debt) in most Central and Southeast European countries exceeded 10% of GDP.

ChallengesCentral and Southeast Europe faces a number of fiscal policy challenges. Urgent financing needs within the public sector of most countries is resulting in a sharper focus on tax collection.

The economic downturn has had varied impacts across Central and Southeast Europe. A key one, though, has been changes in fiscal and tax policy aimed at increasing the effectiveness of tax collection.

The impact of the crisis on fiscal policies

4 Special edition Ernst & Young

Fiscal policy Credit: De Napoli agency

Gateway to the Baltic Sea: the Port of

Tallinn. Due to its rapid growth, the Estonian

economy has often been described as the Baltic Tiger. In

January 2011, Estonia became a member of

the Eurozone.

DifferencesPublic debt is expected to increase in most Central and Southeast European countries until 2015. One exception will be Estonia, which has outperformed its peers in the region. The highest public debts are expected to be in Greece, Hungary and Poland.

Ernst & Young Special edition 5

Fiscal policy

decline in tax receipts. By contrast, tax systems can also help to cushion the impact of an economic downturn through automatic stabilizers, such as the use of progressive taxes.

Fiscal policy challenges In 2010, the total financing needs (the sum of both government deficits and the stock of maturing debt) in most countries in the region exceeded 10% of GDP, which is high compared with historical levels. However, the situation in most of these countries is more favorable than in advanced economies, where financing needs on average were 25% of GDP in 2010. In Japan, for example, GDP was 3.5 times higher in relative terms, while its financing needs were about 15 times higher than in the new EU Member States.

Public debt is expected to increase further in most CSE countries until 2015 (see graph above). However, the scale of this increase differs across the region. The highest public debts are expected to be in Greece, Hungary and Poland, while Estonia should perform better than the rest of the region. There is a growing risk of

sovereign default in several developed countries in the region, which is clearly mirrored in their unsustainable levels of public debt. Government bond yields in some countries are now much higher than in emerging markets. Furthermore, in the longer term, other factors such as societal aging will put additional pressures on public finance in both advanced and emerging economies.

The CSE’s gloomy long-term outlook Despite the fact that both economic conditions and fiscal balances are expected to improve by the end of 2011, with fiscal adjustments taking place in most CSE countries, it will not be enough to reduce public debt. As such, the long-term outlook for public finances is gloomy. According to the International Monetary Fund (IMF), a substantial reduction of fiscal deficits will still be needed to stabilize public debt in most countries, especially when age-related spending is accounted for. As a result, sharp fiscal tightening is expected in most countries in the coming years, with tax likely to be in the spotlight.

New taxes and tax reforms on the horizonThe financial crisis triggered a debate over several tax reforms that may help to improve financial stability and economic performance. An increase in tax revenues is sorely needed, since a reduction in public expenditure alone will most likely not suffice in many countries. According to OECD and IMF experts, the majority of additional tax revenue will not be attained through tax rate increases. Rather, broadening the tax base, closing tax loopholes, cutting tax expenditures and introducing climate taxes are all measures that may help to increase tax revenues.

One specific area being discussed in many countries is an additional taxation of banks to cover the potential costs of bailouts. There are also plans for additional taxes on capital transactions, especially foreign portfolio investment. Both the OECD and the IMF have suggested that the tax burden should be shifted away from taxes on income and toward those on consumption and property. In short, the new tax landscape will not be easy to navigate, and will be rife with pitfalls for the unsuspecting. Understanding and monitoring these shifts in tax policy, along with the potential financial impact on both companies and employees, is a critical need for any firm operating in the region.

Climate taxes The EU Emissions Trading System is a cap-and-trade scheme that sets a limit on permitted emissions of greenhouse gases. During the trading period 2013–20, a significant amount of allowances will be auctioned by governments, which will provide additional revenues. Estonia could be the real winner of this exercise, as the total revenue from sales of these allowances could reach 327% of its public debt in 2011. Meanwhile, in most of the CSE countries, this percentage is expected to be around 25%.

0

50

100

150

200

Gre

ece

Hun

gary

Pola

nd

Turk

ey

Czec

h Re

publ

ic

Slov

akia

Slov

enia

Rom

ania

Latv

ia

Lith

uani

a

Esto

nia

Adv

ance

d G

20

Gross public debt in selected countries

Source: IMF, Forecasts for 2015

20082015

% of GDP

-20.0

-15.0

-10.0

-5.0

0.0

5.0

10.0La

tvia

Lith

uani

a

Esto

nia

Slov

enia

Rom

ania

Hun

gary

Croa

tia

Bulg

aria

Turk

ey

Slov

akia

Czec

h Re

publ

ic

Mal

ta

Gre

ece

Cypr

ius

Mac

edon

ia F

YR

Pola

nd

EU 2

7

GDP growth during the crisis

Source: European Commission

20082009

Piotr Cizkowicz, PhD, Ernst & Young, Economic Strategy Team

6 Special edition Ernst & Young

Denes Szabo, Partner at Ernst & Young, highlighted in his presentation that transfer pricing is becoming a regular catalyst for tax audits.

• By Denes Szabo

T ransfer pricing is usually a key issue for tax departments and tax administrations, but has been growing in importance over the

past two years. This is being witnessed through an increasing number of tax audits across the globe, with auditors focusing on service charges and financing transactions in particular. Countries all over Europe are strengthening their tax authorities in order to support their increased focus in this area, with transfer pricing being a regular catalyst for tax audits. As a result, this is now probably the number one international tax issue for tax departments.

Both the number and volume of cross-border transactions are exploding, due to increasingly global trade flows and specialized functions performed by individual entities within a

multinational group. At the same time, governments in need of tax revenues are using transfer pricing as a tool to fill budget gaps. Given this, the number of transfer pricing challenges, disputes and litigations are on the rise.

The leading approach to tackle this challenge is to set up a central team, preparing central policy and documentation, while making local adjustments. For Central and Southeast Europe, it is also advisable to prepare local documentation packages. In most countries, this typically improves the outcome of tax audits, rather than relying on centralized documentation. Overall, using the right combination of advance pricing agreements, central and local documentation and ultimately arbitration is the key to dealing with a growing number of challenges.

According to research from Ernst & Young, transfer pricing is currently a very important issue for tax departments.

Transfer pricing – always in focus

RomaniaOECD Guidelines are used as a reference in Romanian law, although the local regulations have certain specific features. Generic multi-country searches are now more frequently chal-lenged on compliance with specific local requirements. The Advanced Pricing Agreement (APA) is still not an effective tool to manage transfer pricing risk because of the time it takes for an agreement to be reached, but the situation is improving. For example, several APAs were recently issued after a long review period.

Czech RepublicThe Czech tax authorities have declared a long-term focus on transfer pricing. As part of this effort, a special task force is being assembled by the new tax “Superauthority.” Local tax authorities are more sophisticated than ever before

and there is a coordinated use of AMADEUS software, even within small offices. There is a particular focus on multinationals with high turnover and specific industries are subject to close media scrutiny, such as automotive or pharmaceuticals. There are stringent transfer pricing audits in place, with an increased focus on compliance. The Advanced Pricing Agreement (APA) is recognized as the primary risk mitigation tool. HungaryThe new OECD Transfer Pricing Guideline chapters have been recognized in Hungarian law, including transfer pricing methods and restructuring. The focus of tax audit scrutiny is on well-known loss-makers, large financing transactions, transfer pricing adjustments and non-Hungarian taxpayers. All tax audits contain a detailed review of core-business

transfer pricing documentation. A review or reconsideration of comparable searches is frequently carried out. Tax professionals find that the Hungarian Tax Authority (NAV) is very open and keen to engage in discussions, but has a robust approach to technical matters.

SlovakiaCurrently, a special task force is being assembled, and will be responsible for all large taxpayers in Slovakia. Special attention will be placed on multinationals with low profitability and businesses with low equity levels. Local tax authorities are far more sophisticated than before, with a coordinated use of AMADEUS as well. Transfer pricing audits are more robust than ever before with documentation requested in all cases. Tax authorities are challenging thin capitalization

by applying a combination of arm’s length and substance over form rules. At the moment, the Advanced Pricing Agreement (APA) is not commonly used.

PolandIn 2011, transfer pricing is one of the priorities of the fiscal control authorities in Poland. Recently, comprehensive tax audits in countries such as Germany or the United States have had an impact on Polish taxpayers. The Polish Ministry of Finance closely follows international developments, such as the work of the OECD and EUJTP. Part of these new developments included adjustments of transfer prices for transactions between Poland and Germany. In Poland, the Advanced Pricing Agreement (APA) remains the only tool for agreeing on transfer prices with tax authorities in advance.

Selected Country updates

Transfer pricing

Ernst & Young Special edition 7

Tax controversy

to the facts and collect the right information. As a result, we see developments that require early disclosure, early reporting and early questioning, all before the tax return is filed. This means that there is a lot of pressure on the tax function itself to be current and to think about the consequences of every item that is going to be reported.

Are the tax authorities getting more organized? Yes, this is also reflected in the increase of simultaneous examinations covering multiple countries and the launch of a joint examination process. This is a logical extension of the peer review on exchange of information. In your presentation at the Regional Tax Forum, you were talking about the new global corporate citizenship concept. How does that have an impact on or change the tax function? This is a separate, yet relevant, development in the field of tax controversy. The “global corporate citizenship” concept refers to taxpayers being “good corporate citizens” and also means that taxpayers need to pay “a fair share of tax.” The tax function is no longer just about reducing cost or managing tax costs. According to some not-for-profit organizations, it is about the redistribution of global wealth.

If a company is seen as interfering negatively with this “redistribution of wealth,” the trend is to publicly vilify it in the media, with potentially significant adverse consequences. These can range from several tax authorities deciding to audit the company simultaneously, to consumers potentially no longer wanting to buy the company’s products or services.

What we are seeing today is beginning to appear in some ways similar to the stigma attached to making use of child labor, or producing products that pollute the environment or create hazardous waste. Whether it will expand further, and actually follow the same path as those issues did, is still hard to say. Nevertheless, it seems clear that the tax function is changing dramatically. Tax is not “just” a cost of business any more, but is becoming much more a “social business card.”

Significant changes are happening in tax at a rapid rate, affecting the form and frequency of tax controversy all around the

world. This new phenomenon is coming to Central and Southeast Europe too, as tax authorities increasingly communicate with each other globally and share leading practices. Adjusting to this new tax controversy landscape is going to be vital for all taxpayers in the very near future. In this interview, Monique van Herksen of Ernst & Young shares her insights on some of the emerging themes and trends.

More and more taxpayers are concerned about the increasing pressure on tax compliance, as tax authorities become more organized in determining when and how to initiate higher assessments, penalties and litigation. What are the key reasons behind this? Monique van Herksen: The first and most relevant issue in tax controversy is the global transparency and exchange of information “wave” that is rippling around the world right now. It started with OECD member states, but it is rapidly encompassing other countries too. Governments are reviewing each other, examining whether or not they have mechanisms in place to collect the right information and if they are actually exchanging the right information quickly and efficiently with treaty partners. So, there is more peer review and peer pressure to collect the right tax information and make that information available to other tax authorities.

Further, the most important development in tax controversy is that, logistically, it is shifting in time. Tax controversy is now starting to play a role much earlier in the tax life cycle. The reason for this change is that governments are realizing that they are less likely to be successful if they wait until the tax return has been filed and for the tax audit to find out whether anything has not been reported according to the rules. If they follow the traditional way of tax auditing, they are often too late. There are procedural disadvantages, as a lot of knowledge and facts get lost over time, can change, or perhaps even be manipulated. Recognizing this, tax authorities are trying to move the controversy phase much earlier in the tax life cycle so as to remain closer

Monique van Herksen is Ernst & Young’s Global Head of Transfer Pricing Controversy and EMEIA Tax Controversy Leader

Tips and hints– Discuss with your

management the holistic concept of taxation. Take taxation as any other condition of the workforce and make sure there is a tax policy in place that reflects this approach.

– Once you have implemented a tax policy, maintain consistency.

– Transparency can help serve as a defense: Inform your entire business of the company’s policy so there are no surprises.

Tax is becoming a social business card, says Monique van Herksen, Ernst & Young’s Global Head of Transfer Pricing Controversy and EMEIA Tax Controversy Leader

The trends of tax controversy

8 Special edition Ernst & Young

Trends & tips Credit: iStockphoto.com / Julien Gille

Trends– Compulsory auditing

of large companies every three years

– Transfer pricing: not only formal reviews anymore; also started informally for SMEs

– Pre-refund VAT audits are almost automatic, with high penalties: large taxpayers can expect a €200,000 assessment on average

– Data mining and analytical tools are being used in audits; risk assessment tools are expected to improve

Tips– Appoint a single point

of contact (external accountants and advisors are accepted for this purpose)

– Review and log documents that you hand over to the inspectors

– Check what is being requested and the authority on which this is based

– Keep in regular contact with the inspectors and try to understand their concerns

Hungary

Tax audits are on the rise nearly everywhere, posing a challenge for firms — especially those not sufficiently prepared.

Tax audits and litigation

The efficiency of tax audits is constantly increasing across Central and Southeast Europe. In a majority of the countries

across this region, an increasing number of tax audits has been observed. However, this increase has not been accompanied by higher transparency in the criteria relating to how taxpayers are selected for tax audits. This is not surprising, as such criteria is usually not clear and precise and are only rarely published, but essentially means that all taxpayers need to be prepared for such an eventuality. Indeed, the most important factor contributing to a successful tax audit outcome, as emphasized by Ernst & Young’s tax controversy leaders in all countries, is the importance of the pre-audit phase. Though it may sound trite, the preparation for a tax audit determines – in the majority of cases – the final outcome of the audit. According to 2011 research from Ernst & Young, Seizing the opportunity in global compliance and reporting, 64% of taxpayers polled experienced unplanned audits, while 45% received unexpected tax assessments. As such, given the multinational nature of business and transactions of the biggest taxpayers, a coordinated preparation

across countries is of utmost importance to successfully navigating a tax audit.

Country-specific trendsThe third Ernst & Young Regional Tax Forum offered a detailed overview of the current trends related to tax audits and litigation across key countries in Central and Southeast Europe. Some of these trends are highlighted here.

Agnieszka TalasiewiczTax Partner, Poland, and Tax Controversy Leader for Central and Southeast Europe

Read more on www.ey.com/gcrsurvey

Ernst & Young Special edition 9

Credit: iStockphoto.com / Artur Bogacki / Narcisa - Floricica Buzlea / Valerie Crafter / Arpad Benedek Trends & tips

Trends– Industry-thematic

tax audits being conducted by tax authorities (for example, major companies within the petroleum industry)

– The introduction of a risk-based audit system is being actively discussed

– Special system established for VAT refund

Tips– If the substance over

form principle is misused, convince tax authorities to accept the taxpayer’s position during the appeal stage

– Envisage the option of going to court if an appeal is not successful

Romania

Trends– Focus is primarily

on VAT – Corporate tax receives

less attention – Personal tax receives

little attention, but social security compliance is targeted by a separate enforcement group

Tips– Have a single

(principal) point of contact to manage the process on the taxpayer’s side

– Proactively manage events and stay in regular contact

– Be ready to appeal within a short deadline to help ensure that any supporting evidence is offered at the tax report stage

Bulgaria

Trends– Inspections are

becoming increasingly efficient

– In most cases, tax inspections are being triggered by applications for refunds of tax overpayments

Tips– Remember that the

decision is not final until it is signed: the tax authorities can change their mind

– Listen to tax inspectors and look for their priorities

– Try to document as much as possible on paper

Poland

Trends– Special tax authorities

and expert inspection teams are being introduced for the largest taxpayers (turnover >€80m)

– Increased focus on more complex issues, with less focus on procedural mistakes

– Investment incentives are at the top of the agenda

Tips– Keep in mind that

good management of a tax inspection from the very beginning is usually the key to success

– Be ready for complex e-testing of primary accounting and tax records (IDEA based)

– Know that taxpayers can and do argue and win cases

Czech Republic

10 Special edition Ernst & Young

Facts & trends Credit: Ernst & Young

regional tax landscape, discuss and debate current issues, and provide guidance on how best to navigate these. Now in its third year, the Forum has become a prominent platform for debating local, regional and global tax issues, with experienced knowledge from Ernst & Young’s tax professionals, as well as independent stakeholders.

One key theme highlighted at the Forum was the fact that governments and tax authorities across the region will be redoubling their efforts to increase tax collection in response to the economic crisis. As part of this effort, they are becoming increasingly sophisticated in their approach from a policy perspective, as well as the degree to which they exchange information and coordinate with other tax authorities. The number of tax audits and inspections is on the

• By Botond Rencz

Tax executives in Central and Southeast Europe today are faced with a multitude of challenges. Dealing with a number

of differing national jurisdictions, multiplied by cross-border issues, transfer pricing and compliance – all of which are of equal significance for multinationals – make tax management within the region particularly complex.

In order to help clients understand and manage these challenges, Ernst & Young hosts an annual Regional Tax Forum as a platform to bring together regional tax executives with some of the most experienced regional and global tax professionals. The focus of the Forum is to help companies better understand the complex

Each year, the Ernst & Young Regional Tax Forum for CSE offers a unique opportunity to tax professionals for exchanging ideas, identifying common challenges and discussing potential solutions moving forward.

1,200 Across Central and Southeast Europe, Ernst & Young has over 1,200 experienced professionals in its Tax practice, including 59 partners.

Ernst & Young’s third annual Regional Tax Forum highlighted the current challenges being faced by tax executives, along with insights and advice on how well to cope with these.

Navigating the tax landscape of Central and Southeast Europe

Ernst & Young Special edition 11

Credit: Ernst & Young Facts & trends

Estonia Latvia Lithuania

Poland Slovakia Hungary

Moldova Romania Bulgaria Turkey Cyprus

Czech Republic Slovenia

Croatia Serbia

Montenegro

Albania FYR of Macedonia

Greece Malta

This approach offers you the following benefits: – Consistent range of services, methodologies

and applicable professional and technical standards

– Utilization of a “single point of contact” service – Reasonably reduced complexity of managing

tax risk across multiple jurisdictions – Improved tax position by leveraging cross-

border opportunities and issues

By providing a coordinated approach across Central and Southeast Europe, Ernst & Young strives to deliver the enhanced quality of service, speed of response and return on investment that is demanded of a preferred tax advisor.

rise, meaning that multinationals must be better prepared for a visit from the tax authorities – and to do so well in advance of any potential tax controversy or litigation.

Ernst & Young: helping manage tax complexityFor Ernst & Young’s tax practice in the region, it is our primary imperative to proactively address the complexity of tax matters, and provide regional tax and finance executives with the appropriate and timely information, advice and options needed to successfully manage and achieve their business objectives. We also play a vital role in helping to develop and implement compliance processes for our clients, as well as advising on overall efficiency. Our global network, combined with our in-country experience within the region, puts us in a position to deliver experienced recommendations on how to manage tax risks and opportunities for both regional and local tax executives.

In order to deliver exceptional client service to regional tax and finance executives, we provide an account team that is geographically tailored to transcend jurisdictional borders, in order to fit our clients’ own managerial structure. Led by a senior tax partner as a regional account leader, we offer a single point of contact and coordination in order to help bring clarity to the complexities of the tax and legal landscape. This approach increases efficiency, adds value to engagement execution, and allows us to leverage our global organization to bring knowledge, experience and alternatives to your doorstep. This global knowledge and experience helps us retain the confidence of our clients’ investors, manage risks, strengthen controls and grasp opportunities that may help them grow their businesses profitably.

Tax professionals discussing a wide range of topics at the two-day forum in Warsaw.

Source: Ernst & Young Central and Southeast Europe

Ernst & Young Central and Southeast Europe Tax services

ImprintPublisher:Ernst & Young EMEIA TaxMaagplatz 1, 8005 Zurich, Switzerland

Marketing Director: Alfred RaucheisenAssociate Marketing Director: Monica KremerMarketing Manager: Sandra Sasson

Program Manager: Botond RenczContent Advisor: Robin Wendell-ZabielowiczOnline Manager: Mikael Enoksson

Publishing House:Infel AG, Militärstrasse 36, 8021 Zurich, Switzerland

Publishing Director: Elmar zur BonsenEditor:James Watson Art Directors: Guido Von DeschwandenBernadette Schenker Project Manager: Michèle MeissnerPicture Editor:Matthias Jurt

Printer: Rüesch Druck AG9424 Rheineck, Switzerland

All rights reserved. Contents of this publication may not be reproduced whole or in part without written consent of the copyright owner.

Ernst & YoungAssurance | Tax | Transactions | Advisory

About Ernst & Young Ernst & Young is a global leader in assurance, tax, transaction and advisory services. Worldwide, our 141,000 people are united by our shared values and an unwavering commitment to quality. We make a difference by helping our people, our clients and our wider communities achieve their potential.

Ernst & Young refers to the global organization of member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit www.ey.com

About Ernst & Young’s Tax services Your business will only achieve its true potential if you build it on strong foundations and grow it in a sustainable way. At Ernst & Young, we believe that managing your tax obligations responsibly and proactively can make a critical difference. Our global teams of talented people bring you technical knowledge, business experience and consistent methodologies, all built on our unwavering commitment to quality service — wherever you are and whatever tax services you need.

Effective compliance and open, transparent reporting are the foundations of a successful tax function. Tax strategies that align with the needs of your business and recognize the potential of change are crucial to sustainable growth. So we create highly networked teams who can advise on planning, compliance and reporting and maintain effective tax authority relationships — wherever you operate. You can access our technical networks across the globe to work with you to reduce inefficiencies, mitigate risk and improve opportunity. Our 25,000 tax people, in over 135 countries, are committed to giving you the quality, consistency and customization you need to support your tax function. It’s how Ernst & Young makes a difference.

© 2011 EYGM Limited. All Rights Reserved.EYG No. DL0462

This publication contains information in summary form and is therefore intended for general guidance only. It is not intended to be a substitute for detailed research or the exercise of professional judgment. Neither EYGM Limited nor any other member of the global Ernst & Young organization can accept any responsibility for loss occasioned to any person acting or refraining from action as a result of any material in this publication. On any specific matter, reference should be made to the appropriate advisor.

www.ey.com

If you wish to register for upcoming Ernst & Young CSE tax events, please complete this form and send it back to the address below. Please note that most of our invitations are sent electronically.

AlbaniaBulgariaChinaCroatiaCyprusCzech RepublicEstoniaGermanyGreeceHungary

LatviaLithuaniaLuxembourgMacedoniaMaltaMoldaviaNetherlandsPolandRomaniaRussia

SerbiaSlovakiaSloveniaTurkeyUkraine

Specific indirect tax planningGlobal mobility of employees in CSE region

Please specify areas/topics of your interest

Pleace send the form to Ernst & Young: Sandra Sasson, CSE Marketing & Communications, 11th km National Road Athens-Lamia, 144 51, Athens, Greece Tel: +30 210 2886 032 | Fax: +30 210 2886 910 | Email: sandra.sasson@gr.ey.com

Mr/Mrs:Last Name:First Name:Title:

Company:Adress:Email:Tel.:

Registration form

Ernst & Young Tax eventsCentral and Southeast Europe