TaxMatters@EY - September 2013
Publications and articles
Tax Alerts — Canada
- 12 July 2013 technical amendments: foreign affiliates and other measures
2013 Issue No. 31
On 12 July 2013, the Department of Finance released draft legislation containing a range of proposed amendments to the federal Income Tax Act and Regulations applicable mainly in relation to investments in foreign affiliates.
- Character conversion transactions – transitional measures
2013 Issue No. 32
On 11 July 2013, the Department of Finance released revised transitional measures applicable to the “character conversion” rules that were proposed as part of the 2013 federal budget.
- OECD releases BEPS Action Plan
2013 Issue No. 33
On 19 July 2013, the OECD released its Base Erosion and Profit Shifting (BEPS) Action Plan, which lays out its 15 specific focus areas of international tax law and practice for the next phase of its BEPS project.
- More details on OECD BEPS Action Plan
2013 Issue No. 34
More details on OECD BEPS Action Plan.
- Teletech decision exposes potential pitfalls in obtaining double tax relief
2013 Issue No. 35
The Federal Court of Canada decision in the TeleTech case exposes a number of potential pitfalls for Canadian companies seeking to resolve double taxation arising from transfer pricing on transactions with non-arm’s-length parties.
- 2013 Global Transfer Pricing Survey: the shift toward risk management
2013 Issue No. 36
Transfer pricing remains the number-one tax issue facing multinational companies, but their focus has shifted towards risk management. That’s the primary observation from EY’s 2013 Global Transfer Pricing Survey.
- Changes to the large business simplified method and clarification for its application to expenses incurred before 1 January 2014
2013 Issue No. 37
The Agence du revenu du Québec announced changes to the large business simplified method for calculating input tax refunds in respect of expense reimbursements, and clarified the application of the method to expenses incurred before 1 January 2014.
- OECD issues Revised Discussion Draft on the Transfer Pricing Aspects of Iintangibles
2013 Issue No. 38
On 30 July 2013, the OECD issued a revised discussion draft on the transfer pricing aspects of intangibles. The document updates the initial discussion draft issued on 6 June 2012 and has been amended in the light of comments received during the public consultation process held in November 2012.
- The OECD invites public comments on the white paper on transfer pricing documentation
2013 Issue No. 39
As part of its project on transfer pricing simplification, the OECD released a white paper on transfer pricing documentation on 30 July 2013. The document is intended to initiate an international discussion of ways in which compliance with transfer pricing documentation requirements can be made simpler and more straightforward.
- Urgent action may be required on upstream loan rules
2013 Issue No. 40
On 26 June 2013, Bill C-48, Technical Tax Amendments Act, 2012, received Royal Assent. Due to the effective dates of the upstream loan rules contained in this legislation, urgent action may be required by some taxpayers to avoid significant adverse tax implications, or to file amended tax returns.
- CRA MAP report reflects improved timelines and continued high volume of CRA Canada-initiated cases
2013 Issue No. 41
On 8 August 2013, the CRA released its Mutual Agreement Procedure (MAP) Program Report for the fiscal year ending 31 March 2013. The report provides an overview of the operations of the MAP program.
- Government proposes changes to foreign affiliate dumping rules
2013 Issue No. 42
On 16 August 2013, the federal government proposed draft legislation to introduce a number of revisions to the foreign affiliate dumping rules that were enacted on 14 December 2012. These revisions reflect certain lingering concerns that were raised during consultations on the various versions of the proposals before and even after enactment.
- Finance launches consultation on measures to prevent treaty shopping
2013 Issue No. 43
On 12 August 2013, the Department of Finance released a consultation paper titled Treaty shopping — the problem and possible solutions. The paper’s release follows the recently issued OECD Action Plan on Base Erosion and Profit Shifting.
Publications and articles
Exceptional magazine, July–December 2013
The concept of entrepreneurship is usually associated with launching and building a business, but as you will see from this edition of Exceptional, some of the most entrepreneurial business leaders have never started a company.
Global Tax Policy and Controversy Quarterly Briefing, July 2013
This global publication studies themes and issues related to the continually changing tax policy and tax enforcement landscape. Without question, a key event since our last edition was the OECD’s report addressing base erosion and profit shifting (BEPS). In addition to the BEPS project, our publication also provides updates from the European Commission and a range of other jurisdictions experiencing tax developments.
Tax transparency: seizing the initiative
The public is calling for a clearer picture of organizations’ tax policies and the amount of tax they pay. The recent debate around “fair tax” has raised expectations of the level of tax information multinationals provide. However, many organizations we have spoken to are concerned that increased transparency will not deliver greater understanding but will instead create a potentially significant administrative burden and result in divulgence of commercially sensitive information.
2013 global oil and gas tax guide
EY’s annual guide provides information about oil and gas tax regimes in 74 countries. The guide can help businesses implement local tax legislation, which varies greatly from general corporate tax regimes. It reports that development of unconventional oil and gas — shale oil and gas, in particular — is economically possible under current oil prices and many countries are working on altering their fiscal framework to provide incentives for such projects.
Business immigration alerts and updates
For the latest information on Canadian and US business immigration issues from Egan LLP, a business immigration law firm allied with Ernst & Young LLP in Canada, visit EganLLP.com.
Focus on private business
Because we believe in the power of private mid-market companies, we invest in people, knowledge and services to help you address the unique challenges and opportunities you face in the private mid-market space.
Online tax calculators and rates
Frequently referred to by financial planning columnists, this popular feature on ey.com/ca lets you compare the combined federal and provincial 2012 and 2013 personal tax bills in each province and territory. The site also includes an RRSP savings calculator and personal tax rates and credits for all income levels. Our corporate tax-planning tools include federal and provincial tax rates for small-business rate income, manufacturing and processing rate income, general rate income and investment income.
| EY's Complete Guide to GST/HST, 2013 (21st) Edition |
Editors: Jean-Hugues Chabot, Dalton Albrecht, Sania Ilahi, David Douglas Robertson
Canada’s leading guide on GST includes HST commentary and legislation, as well as a GST–QST comparison. Written by EY indirect tax professionals, the guide is consolidated to 15 July 2013. Available September 2013.