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Subject: Draft "Position Paper" version 0.3; teleconference March 4

Dear all,
I would have liked to attach this directly as a comment to the "Position Paper" document, but the system tells me that I am restricted there to 1000 characters. So my comments/proposals are here:

As a non-native speaker of English I do not share (nor understand) the reservations against the notion of „position paper“, but if there is something unpleasant or questionable associated with that notion, we should certainly avoid it. Is it a “statement of rationale and direction of work”?

It is true that the main and first decision should be about the intended audience: Is it a paper for tax administrators, for tax administrations (which includes not only tax administrators but also IT people, managers, maybe even politicians), or mainly for ourselves and possibly other standardisation institutions, or is it for all of these? Depending on that decision the manner how to cover and the weight to attribute to different topics (XML as a technology, intended direction and results of the committee’s work, relation to other standards and groups) may vary. My own tendency would be not to restrict the audience too narrowly (i.e. not write a paper “for tax administrators”) but to put down the “why and what” for the committee’s work in a document that all of the addressees mentioned above could read to their benefit.

I agree to some extent with the remarks in the last teleconference that the structure of the document can certainly still be amended. Especially  no 5  would probably benefit from restructuring. As there have already been some proposals to that end  in the teleconference and as some of the contributors of these remarks will probably work on structure already,  any more proposals would only be confusing. So I just contribute these isolated issues:

Notion of “client”

I know that it is modern to call more or less everybody a client today. This may help in aiming at a serviceoriented attitude. It may also help in having a common term with CIQ. But even if we want to address our taxpayers as clients, there are other parties involved in the transactions that we will have to cover which play different roles. I would therefore strongly advise to use a more general term at the outset, for me the preference is with “party”.   (In indirect taxation we will often have to deal with the information about two parties – e.g. seller and buyer - , in the EU e-commerce directive there is the “NonTaxablePerson”, in OECD information exchange there are RecipientBeneficialOwner, Payer and agents or intermediates of both, the EU savings directive has comparable parties to deal with.) I therefore propose to change the word “client” to “party” allover the paper  and  to consider whether, in the diagram of 4.2, it is sufficient to say “party data” in order to include also the possibility of several parties, or if it is clearer to say “data of parties involved” .

Questions in 1.2 Document purpose

The first question  (“What are the standards …?”) really is a question, the second is not. As the introductory phrase uses the plural, there is obviously the intention to talk about at least two questions. I daresay the questions are:
-	What standards do already exist that are useful for expressing the data that tax administrations collect and report on?
-	What is still missing?
-	Where there is overlapping: Where should and how can differences be bridged?  Where should and how can existing standards be harmonized? Where do we need to make distinct decisions between existing solutions and what should these decisions be? 

4.1 Why further standards?

At the end of the paragraph: we should avoid to call XBRL and UBL tax specific standards. (Standards with tax related components?)  Also “The OECD standards are:” should read “Tax related OECD standards with relevance to the committees work are:”

5.3 XBRL
In the last sentence instead of “The tax administrations ..” it might be better to say  “Many tax administrations …”

5.7 STF 

Although as the coordinator of the STF group in the OECD I am certainly fond of and proud of STF, I perfectly see that  STF is only emerging to be what we set out to build: the general basis for exchange of tax information between tax administrations. I therefore propose to rephrase the “Recommendations” paragraph a bit more modestly:

“Support the further development of STF as the primary standard for electronic transfer of tax information between jurisdictions by assisting its extension and its convergence with the evolving principles of TAXXML".    

Also I propose to delete the word “other” in the sentence following that recommendation statement (Neither the OECD nor OASIS is a tax jurisdiction.)

Attachment 2:UBL

I am a bit in doubt if the first sentence is really a valid description or definition of UBL. 

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