22 May 2014
Americas Tax Center Weekly Roundup
Latest news — Americas
OECD holds public consultation on transfer pricing documentation and CbC reporting
On 19 May 2014, the OECD held a public consultation on the transfer pricing documentation and country-by-country (CbC) reporting draft, which was released on 30 January 2014. The draft is set to be completed by September 2014. The OECD working party stressed that it is still discussing the best way for filing and sharing of the CbC report and has not reached any final conclusion. It wants to protect confidentiality but also wants to ensure that material can be delivered to all countries on a timely basis. A Tax Alert has details.
OECD holds public consultation on BEPS action on hybrid mismatch arrangements
On 15 May 2014, the OECD held a public consultation on its hybrid mismatch arrangements project (Action 2) under its Action Plan on Base Erosion and Profit Shifting (BEPS). This consultation was an opportunity for interested parties to engage directly with the OECD Secretariat and the country representatives who are responsible for the work on this action item. The OECD is expected to release its recommendations in this area by the target due date of September 2014. A Tax Alert has details.
Ecuadorian FFIs need customer’s authorization before releasing information to US IRS
In Ecuador, foreign financial institutions (FFIs) are required to obtain a customer’s authorization to release any information to the Ecuadorian tax authority and US Internal Revenue Service (IRS) in relation to the US Foreign Account Tax Compliance Act (FATCA). Additionally, all Ecuadorian FFIs must submit the information to the Ecuadorian Tax Authority (SRI) for the respective internal registry before reporting to the IRS. A Tax Alert has details.
Canadian Tax Intelligence publication discusses directors’ liability
Tax Intelligence, a series prepared by the Couzin Taylor law firm allied with EY Canada, covers significant topics and developments in Canadian tax law and administration that impact businesses and taxpayers in Canada and beyond. The latest issue provides an overview of the restrictions on the Canada Revenue Agency in making and accepting settlement offers in tax litigation and examines the circumstances in which a refused offer can be considered in the determination of costs following the trial of a taxpayer’s appeal at the Tax Court of Canada.
Tax Insights for business leaders – new EY publication
Tax law is changing quickly around the world as governments seek to modernize their tax systems to attract investment and boost compliance and revenue. Corporate taxpayers need to engage actively in this debate to help improve the understanding and acceptance of these new laws. The first edition of our new-look magazine, Tax Insights for business leaders, explores the theme of "the future of tax" and examines some of the most important global issues.
Latest Americas edition of EY’s Capital Insights now available
The latest issue of Capital Insights investigates the factors that can give leaders the edge as they seek to expand their businesses. In this issue, the CFO of corporate giant GE gives the inside track on growth and discusses how the company is focusing on infrastructure, innovation and efficiency. Additional features discuss the top five sectors that drive dealmaking, how one of the world’s biggest multinationals is growing in emerging markets, three key rules for mid-market companies to follow, and more.
This week's tax treaty news in the Americas
- Quebec and Bulgaria: social security agreement initialed
- Uruguay and US: intentions expressed to negotiate social security agreement
- Venezuela and Palestinian Autonomous Areas: tax agreement signed
This week's EY Global Tax Alerts
- EU Advocate General issues opinion regarding whether supplier’s infrastructure creates a fixed establishment for VAT purposes (20 May 2014)
- Ecuadorian FFIs need customer’s authorization before releasing information to US IRS (20 May 2014)
- OECD holds public consultation on transfer pricing documentation and CbC reporting (20 May 2014)
- Ministers of participating Member States issue joint statement on the EU Financial Transaction Tax (19 May 2014)
- Malaysia issues clarification of tax-exempt income from foreign fund managers (19 May 2014)
- OECD holds public consultation on BEPS action on hybrid mismatch arrangements (19 May 2014)
- New Zealand issues 2014/15 Budget (19 May 2014)
- Brazil enacts tax reform (15 May 2014)
- EU Advocate General issues opinion regarding cross-border intra-company transactions within a VAT group (15 May 2014)
- Australia issues 2014/15 Federal Budget (15 May 2014)
- China’s State Council issues circular to improve regulatory environments for M&A transactions (15 May 2014)
- Inter-company effectiveness: forecasting, executing and monitoring intercompany pricing (28 May)
Our upcoming BorderCrossings webcast will address how to achieve operational excellence in the execution of inter-company pricing across the inter-company life cycle (e.g., forecasting, processing, monitoring/adjusting and documenting). The webcast will cover a broad range of common issues facing today’s multinational organizations. Register here.
- 2014 tax risk and controversy survey highlights (5 June)
Our 2014 tax risk and controversy survey found that reputation risk, the OECD BEPS project, complex new national legislation, and more robust tax enforcement worldwide are all putting more pressure on tax function resources, processes and technology. Register for the upcoming webcast to hear highlights from the survey of 830 tax and finance executives in 25 jurisdictions. Register here.
Recently archived webcasts now available on-demand
- BorderCrossings: A Conversation with the Director of the US IRS Office of Transfer Pricing Operations
In the latest BorderCrossings webcast, US IRS Office of Transfer Pricing Operations Director Sam Maruca shared the latest on IRS transfer pricing operations, including IRS goals, strategies and tactics in improving taxpayer upfront compliance and making IRS transfer pricing enforcement more effective. Watch it on-demand here.
EY industry, service and issue publications
- Charting the course: A framework to evaluate pension de-risking strategies
- Joint statement by Member States reaffirms plan for EU FTT
- EY - FASB lays out topics it will consider for insurance industry accounting
- Mobile technology in insurance
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