07 June 2013
Americas Tax Center Weekly Roundup
Latest news — Americas
Argentina introduces amendments to rules on tax havens
The Argentine Government has issued a decree modifying the rules on low or nil tax jurisdictions (tax havens). Up until now, the Regulatory Decree to the Income Tax Law contained a list of 87 countries, jurisdictions and territories considered tax havens for tax purposes. Now, the list has been eliminated from the Regulatory Decree and the Federal Tax Authorities have been empowered to establish a new list of countries, jurisdictions, territories and tax systems that will be considered as "cooperators for purposes of fiscal transparency" and will not be considered as tax havens. A Tax Alert has details.
Honduras releases details of tax amnesty program
Decree No. 71–2013 approving a tax amnesty program was published in the Honduran Official Gazette No. 33,128 on 20 May 2013. Under the program, amnesty is generally granted to all taxpayers with pending tax controversies or litigation and taxpayers that have not complied with reporting and payment obligations. Taxpayers who pay their outstanding balance of taxes due will be granted a waiver on the related late payment interest, fines, charges and surcharges accrued up to 31 December 2012. The amnesty period generally began on 20 May 2013 and ends on 31 December 2013. A Tax Alert has details.
Costa Rica issues rules on the deductibility of expenses paid in cash
The Costa Rican Tax Authorities have issued a resolution establishing rules on the deductibility of expenses paid in cash for income tax purposes. The resolution, which is mandatory for all taxpayers and entered into force on 1 June 2013, states: (1) expenses paid in cash in excess of approximately US $2,250 are no longer deductible; (2) expenses paid in cash in excess of approximately US $110, but not exceeding the US $2,250 threshold, are deductible only if certain documentation requirements are met; and (3) as an exception to the above, purchases of goods and services paid by offset are deductible, subject to satisfying certain requirements. A Tax Alert has details.
United Nations launches Practical Manual on Transfer Pricing for Developing Countries
The United Nations Committee of Experts on International Cooperation in Tax Matters has released its Practical Manual on Transfer Pricing for Developing Countries that it began work on in 2009. The manual is designed to be in accordance with the "arm's length principle," an approximation of the market-based pricing provided for in both the UN Model and the OECD Model Tax Conventions. Such an approach seeks to minimize potential double taxation disputes among countries, while combating potential mispricing of internal transactions within a multinational enterprise for profit shifting between jurisdictions. A Transfer Pricing Alert has details.
OECD provides an update on base erosion and profit shifting project
At the annual OECD tax conference in Washington, DC, held on 3-4 June 2013, developments with respect to the OECD’s project on base erosion and profit shifting (BEPS) dominated the discussion. The OECD issued its initial report, Addressing Base Erosion and Profit Shifting, on 12 February 2013. OECD representatives and government officials at the conference provided insights regarding the competing considerations and interests that the OECD is balancing as they move toward finalizing the BEPS workplan for release next month. A Tax Alert has details.
Ernst & Young Global Family Business Center launched
The new EY Global Family Business Center of Excellence will help us tailor our services to address the specific challenges that family-owned businesses face. It is a powerful new online resource that showcases our commitment to family businesses and our unique, market-leading offering. It’s also where you can find our Growth DNA model, which addresses every aspect of the family business agenda and aligns our range of services to address each client’s specific needs.
Infrastructure 2013: Global Priorities, Global Insights — Ernst & Young report
The seventh in a series of global annual reports assessing the state of infrastructure globally and connecting strong infrastructure investment decisions to national and metropolitan prosperity is now available. Produced by the Urban Land Institute and EY, Infrastructure 2013 pinpoints the trends, policies and issues shaping infrastructure in 2013 and beyond. Based on interviews with infrastructure experts, up-to-date research and analysis, and other sources, the report is full of essential information and insights for any infrastructure or land use professional.
New version of Ernst & Young's free Global Tax Guides app available now
We have just released a new version of our EY Global Tax Guides app, which has a more user-friendly interface and now includes our Global Tax Alerts. See tax guides app page on ey.com that features a video. More than 4,700 people have now downloaded our free mobile app, enabling them to easily access our series of global tax guides on their iPads®. The free EY Global Tax Guides accessible app provides access to our series of global tax guides, including the 2013 Worldwide corporate tax guide. Timely Global Tax Alerts are now available on this app to supplement the guides. Easily navigate between 150+ jurisdiction on one app. To obtain the app, go to the Apple iTunes store:http://www.apple.com/itunes/?cid=OAS-US-DOMAINS-itunes.com.
This week's Global Tax Alerts
- European Council calls for expanded disclosure requirements for non-financial and diversity information (6 June 2013)
- Russia announces 2014 tax policy and planning for 2015-2016 (6 June 2013)
- New Russia-Malta Tax Treaty signed (6 June 2013)
- Nigerian tax authorities issue guidance on tax implications of adoption of International Financial Reporting Standards (6 June 2013)
- Netherlands and China sign new tax treaty (5 June 2013)
- Spain - Kuwait tax treaty ratified (5 June 2013)
- India approves initiation of non-binding conciliation process with Vodafone (5 June 2013)
- Honduras releases details of tax amnesty program (5 June 2013)
- Argentina introduces amendments to its rules on tax-havens (4 June 2013)
- OECD provides an update on base erosion and profit shifting project (4 June 2013)
- United Nations launches Practical Manual on Transfer Pricing for Developing Countries (4 June 2013)
- IRS rules no gain or loss on domestication of parent company (4 June 2013)
- South African permanent establishments face further scrutiny (4 June 2013)
- EU financial transaction tax - latest developments (3 June 2013)
- Costa Rican Tax Authorities issue rules on deductibility of expenses paid in cash (3 June 2013)
- German Government announces signing of US-Germany FATCA Intergovernmental Agreement (31 May 2013)
- South Africa transfer pricing related disclosure requirements in the new ITR14 (31 May 2013)
- Mainland China issues guidance for determining beneficial owner status under dividend clause of the tax arrangement with Hong Kong (31 May 2013)
- Australia legislates for public reporting of large companies' incomes and taxes (30 May 2013)