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In this contribution, the authors provide an overview of the implementation of the EU Anti-Tax Avoidance Directives (ATADs) 1 and 2 in the Netherlands. After providing an overview of the implementation process, the authors will analyse and comment on the several amendments made to Dutch corporate income tax law. There is specific focus on the interest deduction limitation rule, controlled foreign company (CFCs), general antiabuse rule (GAAR), and hybrid mismatches. The authors will address certain ambiguities and highlight some potential issues from an EU law perspective. The authors will also briefly discuss recent developments such as the Netherlands’ proposal to unilaterally address certain transfer pricing mismatches and the impact of the ECJ case law on abuse and tax avoidance. This contribution will not examine tax treaty implications. ATAD, ATAD2, EBITDA, earnings stripping, interest deduction limitation, CFC, hybrid mismatch, hybrid, GAAR, documentation requirements.

This report aims to deepen the understanding of barriers to and incentives for the acceptance and use of electronic payments, from the perspective of micro, small and medium retailers (merchants). Developing and accelerating acceptance of electronic payments by these merchants is essential to expanding financial access. A basic transaction account for payments and deposits is considered an entry point to the formal financial system, and can act as a gateway for individuals to adopt other relevant financial services they need to smooth their consumption and manage income shocks. However, equipping individuals with only basic transaction accounts is not sufficient. The use case for payment services becomes increasingly effective as individuals gradually move to a cashless economy, where electronic payments are widely accepted for regular and frequent purchases. The report highlights important dimensions to consider in the efforts to expand electronic payments for merchants.

This report gives an overview of the key results from the analysis of the data collected in a survey conducted in October and November 2012 by the Austrian Institute for small and medium enterprise (SME) research on behalf of the World Bank center for financial reporting reform (CFRR). The survey was carried out using an online questionnaire and captures data from more than 780 SMEs that are representative of the Austrian SME sector. The primary purpose of this report is to assist the accounting and auditing profession, policy makers, and users of financial information in understanding the value and the constraints of SMEs’ financial reporting practices. It also feeds into a broader CFRR study on corporate financial reporting reform in Austria. The report presents the results of the survey grouped by topical areas as follows: accounting practices in Austrian SMEs; auditing financial statements; SME financing; and financial reporting and access to finance.

A well-functioning and inclusive financial sector is critical for efficient resource allocation leading to increased productivity, greater investment, higher overall levels of economic growth, and lower inequality. This is particularly critical in Iraq, where years of political instability and violence have impeded the development of a robust private sector. Microfinance services in Iraq are still nascent and far from meeting their full potential. This diagnostic report aims to present the microfinance landscape in Iraq, its legal and regulatory framework, and potential policy improvements to enhance the operating environment. It aims to inform public and private sector stakeholders on the regulations and laws affecting the development and strategic direction of the microfinance sector. The policy recommendations presented are designed to address factors preventing greater growth and outreach, with the goal of promoting inclusive financial sector development in Iraq.

Jamaica has experienced 30 years of low economic growth and high fiscal deficits, with a significant impact on the development of the financial sector. As part of the overall growth and competitiveness reform agenda, the authorities have embarked on ambitious financial sector legislation reforms to address weaknesses. Lack of access to credit and equity constrain Micro, Small and Medium Sized Enterprise (MSME) operations and growth, and ultimately their contribution to the economy. High interest rates and low penetration of credit to households and MSMEs can be explained by high credit risk as a result of high information asymmetries in the market, as well as limited competition in the banking sector. The authorities should complete the establishment of a regulatory and supervisory framework for deposit-taking institutions proportionate to the risks and the activities they undertake. The impact of public policies has been limited and programs on housing, MSME finance, and agriculture finance would be welcomed to address market gaps, in support of financial inclusion. The financial inclusion agenda also requires a comprehensive strategy on consumer protection regulation and supervision.

The Global Financial Inclusion (Global Findex) database, launched by the World Bank in 2011, provides comparable indicators showing how people around the world save, borrow, make payments, and manage risk. The 2014 edition of the database reveals that 62 percent of adults worldwide have an account at a bank or another type of financial institution or with a mobile money provider. Between 2011 and 2014, 700 million adults became account holders while the number of those without an account—the unbanked—dropped by 20 percent to 2 billion. What drove this increase in account ownership? A growth in account penetration of 13 percentage points in developing economies and innovations in technology—particularly mobile money, which is helping to rapidly expand access to financial services in Sub-Saharan Africa. Along with these gains, the data also show that big opportunities remain to increase financial inclusion, especially among women and poor people. Governments and the private sector can play a pivotal role by shifting the payment of wages and government transfers from cash into accounts. There are also large opportunities to spur greater use of accounts, allowing those who already have one to benefit more fully from financial inclusion. In developing economies 1.3 billion adults with an account pay utility bills in cash, and more than half a billion pay school fees in cash. Digitizing payments like these would enable account holders to make the payments in a way that is easier, more affordable, and more secure.

By increasing access to finance for out-of-reach households and families, microfinance continues to be an essential tool for improving livelihoods at the base of the pyramid. The last 20 years have seen remarkable growth in the microfinance sector. From its early stages in small-scale microenterprise lending, through its commercial expansion to offer savings and a broad array of financial services to low-income customers, to its entry into new markets and incorporation of technological innovations, microfinance is ensuring that an ever-greater number of households have permanent access to a range of high-quality and affordable financial services. The microfinance industry is estimated at $60 to $100 billion globally, where several thousand microfinance organizations reach an estimated 200 million clients, most of whom were not previously served by the formal financial sector. However, 2.5 billion adults still lack access to formal financial services. Financial services for low-income people are an important factor when it comes to poverty reduction, as it enables them to build assets, increase incomes and reduce their vulnerability to economic stress. Moreover, microfinance continues to be an important tool when it comes to empowering women. IFC is the World Bank Group s main investor in microfinance, working with around 300 microfinance institutions (MFIs) and SME-focused financial institutions, which provide financial services in 91 countries. IFC is also one of the leading global investors in terms of volume. In fiscal year 2014, we committed $519 million in 43 projects with MFIs. Our cumulative investment portfolio in microfinance exceeded $3.5 billion, with outstanding commitments of $2.0 billion. In fiscal year 2014, IFC advisory services comprised $74.2 million, representing advisory assistance for 86 projects. This smart book, titled from small beginnings to great opportunities, presents practical lessons learned from the work that authors have been doing on microfinance projects over the last twenty years. From launching the Microfinance Enhancement Facility to help the industry stay afloat during the time of crisis, to working on a project to support microfinance clients to fulfill their housing dreams, these narratives are both engaging and insightful.

This impact evaluation reviews the investment climate (IC) reform programs implemented by the World Bank Group (WBG) in Burkina Faso, Liberia, Rwanda, Sierra Leone, and South Sudan. It follows a study carried out in 2011 across the same countries. The purpose of the evaluation is to update, expand, and deepen the initial analysis within the framework of the earlier study, in order to gain a better understanding of the impact and sustainability of the IC reform activities implemented by the WBG. The evaluation covers a total of 25 IC-related projects implemented by the WBG in the five countries since the mid-2000s. The evaluation consists of three main elements, namely: a review of the outcomes achieved by the IC programs; an analysis of how IC reforms translate into impacts that is into tangible benefits for private firms and for the economy as a whole; and an assessment of the sustainability of IC reforms. The result is a significant improvement in the overall quality of the business environment in the five countries. This report is structured as follows: section one gives introduction. Section two provides an overview of the context in which the WBG programs were implemented, with a short presentation of the salient features of the five countries; section three briefly reviews the activities undertaken by each WBG program; section four analyzes the outcomes of the IC reform programs, with a review of the reforms supported, of the influence of these reforms on the business environment, and of the private sectors perceptions of IC reforms; section five reviews in detail the impact of IC reform programs, providing estimates of both direct impacts (cost savings) and indirect impacts (changes in enterprise formation and formalization, investment, and employment); section six analyzes the sustainability of IC reforms, with respect to both current and prospective sustainability and with an analysis of the main factors influencing sustainability; and finally, section seven summarizes the key findings of the evaluation.

Over the past few years, Microfinance Institutions (MFIs) in Iraq have emerged as credible sources of financing for low-income households and entrepreneurs, both underserved by conventional banks. Microfinance services in Iraq, however, are still nascent and far from meeting their full potential. Similar to many countries in the MENA region, MFIs in Iraq were set up as non-governmental organizations (NGOs) supported by a steady influx of donor funding. While these NGOs were initially able to grow through donor support, they are now struggling to meet increasing client demand as donor resources have dwindled, preventing them from making the necessary investments in capital and infrastructure to meet growing client demand. Many countries address this funding challenge by allowing institutions to provide financial services as companies or banks, helping them raise capital, provide new services, and increase their outreach in a sustainable manner. A similar path could be envisioned in Iraq, but is currently obstructed by regulatory hurdles. This diagnostic report aims to present and assess the current microfinance landscape in Iraq, including the legal and regulatory framework, recommend policy improvements to enhance the sustainability and operating environment for MFIs and their clients. This report argues that the current legal and regulatory environment for microfinance in Iraq hinders the growth and sustainability of the sector and furthermore advocates several short and medium term policy recommendations to enhance the overall operating environment for MFIs, the sustainability of the sector, and impact for clients.

This update considers new findings since the initial Stocktaking report, substantiating the contribution of the private sector, and of small and medium enterprises (SMEs) in particular, for new jobs and investment. These findings further illustrate the key role access to finance plays in SMEs abilities and willingness to add jobs including the special circumstances of fast-growing SMEs, or gazelles. The new findings further detail availability and gaps in SME financing, including for specific subsectors such as women-owned firms and agri-enterprises. New trends include progress made in recent years to improve financial markets infrastructure, and expanded lending in countries such as China, which have made progress in this area. The findings also include key private sector innovations pioneered by the SME Finance Challenge winners and other private sector institutions, focusing on key sector opportunities (such as agribusiness and energy), product innovation (such as expanded local currency options), and risk management alternatives. The new findings and trends highlight the potential of collaborative platforms that have emerged from the G-20/GPFI (Global Partnership for Financial Inclusion) process to combine resources to improve SME access to finance, and some of the major outstanding issues and obstacles these platforms might address. The conclusion provides recommendations for priority issues and work areas for G-20/GPFI attention.

The importance of small and medium enterprises (SMEs) to economic development and job creation is increasingly recognized across the world. With an expected 58 percent of gross value added in 2012, SMEs are perceived to be the backbone of the economy especially within the European Union (EU). Although they faced particularly challenging economic conditions in 2011-12, SMEs within the EU still account for more than 98 percent of all enterprises and 67 percent of total employment. For such businesses, access to finance is a key factor for business start-up, development, survival, and growth. In September-October 2012, the World Bank Centre for financial reporting reform (CFRR) surveyed Austrian banks with a view to understanding the role played by financial information and audits in lending decisions. Respondents to the survey represent approximately one third of the sector based on total assets. The survey also assessed how banks measure the quality of the financial information they receive as part of a loan application. The purpose of this report is to inform the accounting and auditing profession, policy makers, and SMEs and their representative institutions about banks’ requirements and expectations regarding the scope of financial information provided by SMEs when applying for a credit.

Movable assets tangible or intangible often account for most of firm's capital stock. Thus it is important for jurisdictions to develop adequate laws on secured transactions to allow borrowers and lenders to recognize movable assets as collateral, supporting financing secured with such assets. Though the legal and regulatory framework is essential to any secured transactions system, the efficacy of a secured transactions law also requires an effective registration mechanism for interests in movable property. This report focuses on analysis of such institutions, highlighting the importance of a publicly accessible registry where information on interests in movable assets can be registered. The main goals of collateral registries are to provide public notice of interests in movable assets and to establish priority in the assets described in the notice for secured creditors. This report also addresses the different registration mechanisms for security interests in movable property and their effectiveness in achieving the two goals stated above. It does so using the results of a 2010 World Bank Group survey on collateral registries. The report emphasizes the practices and features available in different registries and key characteristics of effective collateral registries. The experiences of jurisdictions that have instituted best practice registries show how technology can improve the efficiency of collateral registries.

Doing business sheds light on how easy or difficult it is for a local entrepreneur to open and run a small to medium-size business when complying with relevant regulations. It measures and tracks changes in regulations affecting 10 areas in the life cycle of a business: starting a business, dealing with construction permits, getting electricity, registering property, getting credit, protecting investors, paying taxes, trading across borders, enforcing contracts and resolving insolvency. In a series of annual reports doing business presents quantitative indicators on business regulations and the protection of property rights that can be compared across 183 economies, from Afghanistan to Zimbabwe, over time. This economy profile presents the doing business indicators for Eastern Europe and Central Asia (ECA). To allow useful comparison, it also provides data for other selected economies (comparator economies) for each indicator. The data in this report are current as of June 1, 2011 (except for the paying taxes indicators, which cover the period January-December 2010).

Doing business sheds light on how easy or difficult it is for a local entrepreneur to open and run a small to medium-size business when complying with relevant regulations. It measures and tracks changes in regulations affecting 10 areas in the life cycle of a business: starting a business, dealing with construction permits, getting electricity, registering property, getting credit, protecting investors, paying taxes, trading across borders, enforcing contracts and resolving insolvency. In a series of annual reports doing business presents quantitative indicators on business regulations and the protection of property rights that can be compared across 183 economies, from Afghanistan to Zimbabwe, over time. This economy profile presents the doing business indicators for European Union. To allow useful comparison, it also provides data for other selected economies (comparator economies) for each indicator. The data in this report are current as of June 1, 2011 (except for the paying taxes indicators, which cover the period January December 2010).

This technical note on access to finance addresses six questions: 1) what is the access to and use of financial services in the Philippines, how does it vary, and how does it compare to other countries? 2) What financial services are available to different market segments? 3) How do different categories of financial institutions contribute to outreach, and what is their potential to expand outreach? 4) How does the regulatory environment support access to finance? 5) What financial infrastructure is available to make credit decisions? 6) What are the results of government policies or programs to promote access to financial services? The note concludes with recommendations to improve access to finance. An estimated 30 percent of Filipinos use formal financial services. This is lower than the East Asia region average. Access to finance has improved since the 2002 Financial Sector Assessment Program (FSAP). The provision of financial services to low-income individuals has expanded. The Philippines has received international recognition for its favorable regulatory policies to promote pioneering use of mobile payments technology and its microfinance regulatory framework.

Doing Business sheds light on how easy or difficult it is for a local entrepreneur to open and run a small to medium-size business when complying with relevant regulations. It measures and tracks changes in regulations affecting 10 areas in the life cycle of a business: starting a business, dealing with construction permits, getting electricity, registering property, getting credit, protecting investors, paying taxes, trading across borders, enforcing contracts and resolving insolvency. In a series of annual reports Doing Business presents quantitative indicators on business regulations and the protection of property rights that can be compared across 183 economies, from Afghanistan to Zimbabwe, over time. This economy profile presents the Doing Business indicators for China. To allow useful comparison, it also provides data for other selected economies (comparator economies) for each indicator. The data in this report are current as of June 1, 2011 (except for the paying taxes indicators, which cover the period January- December 2010). The data not only highlight the extent of obstacles to doing business; they also help identify the source of those obstacles, supporting policy makers in designing regulatory reform.

The world development report 2010 estimates that an additional $200 billion per year of climate-related financing is needed in developing countries between now and 2030 to keep global average temperature rise within 2 degrees Celsius. Developing countries face increased financing challenges over coming decades as they seek to pursue economic development along a lower emission trajectory. The goal of this paper is twofold: i) to provide greater information and clarity on these three mitigation-related climate financing instruments available for the World Bank Group (WBG) and their application in the context of specific projects and national policy frameworks; and ii) to draw lessons for the broader development community on how resources from different climate financing instruments can be combined for expanded impact, increased leverage, and enhanced efficiency. This paper represents an initial contribution to this field and will be followed by papers focusing on guarantees for low-carbon growth support for the private sector and the challenges of financing climate resilience and adaptation.

Purpose: The overall purpose of this thesis is to provide an analysis of the effects of the documentation requirements on transfer pricing and provide a clearer picture of the documentation requirements in transfer pricing. Furthermore, the purpose is to analyze whether the chosen method of Superfos is adequate related to the new regulations. Background: In 2007, new regulations concerning the documentation of transfer pricing was enacted in Swedish law based on OECD guidelines. This change has led to new internal guidelines for companies regarding their transfer pricing work since the requirements apply to both Swedish owned companies and foreign owned companies. Furthermore, with this change, a great uncertainty about the requirements is shared by companies. Method: This thesis has been conducted as a qualitative case study with Superfos as the case company. A deductive approach has been used and the collection of data consists of both primary and secondary data. Primary in the form of an interview with the finance manager at Superfos and secondary through the use of the Swedish tax authority's stated guidelines concerning transfer pricing as well as books, journals and databases. Conclusion: In the conclusion we present a clarifying model of the documentation in transfer pricing based on the data collected for this thesis. In six steps, a clarifying picture of the overview, company structure, transactions identification, functional analysis, comparability analysis and results is provided.

According to the arm’s length principle, transactions between associated multinational en-terprises (MNE) shall be based on the same conditions as transactions between unrelated parties. This means that intra-group prices on cross-boarding transactions must be at arm’s length range and consistent with conditions in the open market. The arm’s length principle is expressed in article 9.1 of the OECD Model Tax Convention and Chapter 14 section 19 of the Swedish Income Tax Act. When transfer pricing between associated MNEs is not reflecting the arm’s length princi-ple, states face the possibility of losing tax revenue. The majority of OECD member coun-tries have implemented national documentation requirements and involve enterprises to present documentation on their transfer pricing. This obligation increases the possibilities for Tax Authorities to control whether or not a company follows the arm’s length princi-ple. Chapter V of the OECD Guidelines provides general guidance in this matter. Within the EU the transfer pricing forum JTPF, has developed a standardized model for docu-mentation known as the EUTPD. Application of the EUTPD depends on the MNEs themselves but also on national requests. The Swedish legislator intends to implement national documentation requirements through the Government Bill 2005/06:169 “Effektivare Skattekontroll”. The regulation is likely to become effective 1 January 2007. Regardless that the burden of proof still lies on the Tax Authorities, MNEs are obligated to produce documentation that will be used as evidence of their transactions. The bill is drafted as a legislative framework and the implication will be developed through further directions from the Tax Authorities. Court Law will also be significant in how the legislation is applied. This thesis concludes that the proposed regulation is unclear and therefore stands to coun-teracts or undermines the purposes behind the legislation. Since transfer pricing is not an exact science it is logical that the regulation be proposed as a framework, which would ren-der the possibilities for extensive interpretations. However, indistinctive rules would not increase neither the awareness nor the predictability concerning transfer pricing and docu-mentation requirements. Considering that the majority of MNEs in Sweden are small and medium sized companies and not always familiar with the arm’s length principle, the legis-lator should have expressed the documentation requirements more precisely. Nonetheless, since the enquiries will most likely increase, enterprises will be forced to allocate resources on their transfer pricing and documentation. This legislation will in turn increase the aware-ness and predictability in the long-term.

As the globalization of companies increases day by day, the need for a clear and comprehensible legislation to overcome the problems with transfer pricing transactions increases as well. Incorrect pricing in transfer pricing situations between companies with close economic ties to each other makes countries risk parts of their taxation income. Swedish legislation uses the internationally accepted arm’s length principle to regulate the transfer pricing transactions. Through the correction rule, the rule is upheld that the pricing between two companies with close economic ties to each other must apply to the same conditions as it would have been if it was between two companies without close economic ties to each other. To ensure that enough material is provided to base the assumption whether or not the correction rule has been followed or not, Swedish legislation provides a number of paragraphs to regulate the matter. The legislation is spread all over and is hard to interpret. The question rises whether this is against the rule of legal certainty or not. The taxation authority has provided a proposition on new legislation with tougher documentation requirements where it also wants to give itself part of the power by through directions exactly define what the documentation shall include. Yet again the question is raised whether or not this is against the rule of legal certainty or not. I takt med att globaliseringen av företag ökar, ökar också behovet av en klar och tydlig lagstiftning för att överkomma problemen med internprissättningstransaktioner. Vid oriktig prissättning vid transaktioner mellan företag i ekonomisk intressegemen-skap riskerar länder att gå miste om delar av sin skattebas. Svensk lagstiftning använder sig av den internationellt accepterade armlängdsprincipen för att reglera internprissättningstransaktioner. Genom korrigeringsregeln regleras att prissättningen mellan två företag i ekonomisk intressegemenskap måste ske under samma förutsättningar som skulle ha gällt mellan två företag utan ekonomisk intressegemenskap. För att få underlag till huruvida korrigeringsregeln har följts eller inte finns ett antal lagrum i svensk rätt som reglerar dokumentationskrav. Denna lagstiftning är spridd och anses vara svårtolkad. Frågan uppstår om detta strider mot rättsäkerheten. Skatteverket har kommit med ett förslag på ny lagstiftning med skärpta dokumentationskrav där man dessutom vill ge sig själv delar av makten att genom föreskrifter exakt bestämma vad dokumentationen skall innehålla. Återigen väcks frågan om det-ta är förenligt med rättssäkerheten.

One of the most significant obstacles in working with LCA and other system analytical tools where enviromental data are used, is the availability of adequate and well-documented inventory (environmental) data. Furthermore, it is preferable if the quality data has been reviewed to some degree. Both process knowledge and environmental competence are needed in order to review environmental data. The Sirii Environmental Data Network holds this unique competence profile, which enables the network to review environmental data with respect to the correctness of documentation as well as the reasonableness of the numerical value. The routine for review of Sirii SPINE documented data is presented in this report. One of the most significant obstacles in working with LCA and other system analytical tools where enviromental data are used, is the availability of adequate and well-documented inventory (environmental) data. Furthermore, it is preferable if the quality data has been reviewed to some degree. Both process knowledge and environmental competence are needed in order to review environmental data. The Sirii Environmental Data Network holds this unique competence profile, which enables the network to review environmental data with respect to the correctness of documentation as well as the reasonableness of the numerical value. The routine for review of Sirii SPINE documented data is presented in this report.