24 January 2014
Americas Tax Center Weekly Roundup
Latest news — Americas
OECD provides update on BEPS Action Plan
On 23 January 2014, the Organisation for Economic Cooperation and Development (OECD) hosted a webcast on the ongoing project to address base erosion and profit shifting. A replay of the webcast can be found on the OECD website. The webcast provided an overview of the OECD's activity with respect to its July 2013 Action Plan on Base Erosion and Profit Shifting. A Tax Alert provides details.
Canada launches Offshore Tax Informant Program
On 15 January 2014, the Canada Revenue Agency (CRA) officially launched its new Offshore Tax Informant Program. First announced in the 2013-14 federal budget, the program is one of five new measures aiming to crack down on international tax evasion and aggressive tax avoidance. It will allow the CRA to pay individuals with information about major international tax non-compliance a percentage of the federal tax collected as a result of the information provided. A Global Tax Alert provides details.
New Argentina-Spain tax treaty published
On 14 January 2014, the Spanish Government published in the Official Gazette the new tax treaty entered into by Spain and Argentina. The treaty will retroactively apply as from 1 January 2013. The new treaty replaces the treaty entered into by Spain and Argentina in 1992, which was unilaterally terminated by the Argentine tax authorities as from 1 January 2013. A Tax Alert, prepared by EY’s Spanish Tax Desk in New York, provides additional details.
Guatemala postpones transfer pricing regulations
A Tax Alert is now available on Guatemalan Decree 19-2013, issued 20 December 2013, reforming the Tax Legislation Update (TLU). TLU was published through Decree 10-2012 of 5 March 2012 and established the transfer pricing regulations, as well as other tax provisions, in effect since 1 January 2013. Among the approved reforms, Decree 19-2013 postpones the application of the transfer pricing regulations to 1 January 2015. Nevertheless, Decree 19-2013 states that the tax authorities are still entitled to request certain information related to the TLU to create their databases.
Canadian tax law series discusses rectification in a tax context
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 examines the availability of the rectification remedy in Canada in light of the pertinent tax jurisprudence, considering both common law and civil law perspectives, as well as the position of the tax authorities and other potentially available remedies
EY Global banking outlook 2014-15: Transforming banks, redefining banking
Five years after the global financial crisis, many aspects of the banking industry are unrecognizable when compared to the pre-crisis era, despite a global economic recovery that seems finally to be gaining traction. In this environment, banks have been struggling to restructure themselves and rehabilitate the industry at large without neglecting the changing expectations of customers and shareholders. Our latest global bank report discusses five unstoppable forces that will drive banks to change over the next few years.
This week's tax treaty news in the Americas
- Barbados and Bahrain: tax treaty enters into force
- Brazil and France: social security agreement approved by Brazilian Congress
- Mexico and Panama: free trade agreement negotiations held
- Mexico and Peru: tax treaty ratified by Peru
- Panama and Israel: tax treaty details available
- Panama and United Arab Emirates: tax treaty enters into force
This week’s EY Global Tax Alerts
- Guatemala postpones transfer pricing regulations (22 January 2014)
- European Commission invites comments on notice regarding state aid definition with specific examples (22 January 2014)
- Czech Republic expands treaty network as of 1 January 2014 (22 January 2014)
- Spanish Central Tax Court re-characterizes price under procurement contracts as a deemed royalty and denies use of "secret comparables" (21 January 2014)
- India’s Delhi Tribunal rules sales promotion activity of Liaison Office is taxable (21 January 2014)
- Cyprus expands treaty network as of 1 January 2014 (20 January 2014)
- Updated US list of foreign currency contracts subject to IRC Section 1256 (17 January 2014)
- Double Tax Treaty between Luxembourg and Kazakhstan is in force (17 January 2014)
- Updated 2013 US IRC Section 1256 qualified board or exchange list (17 January 2014)
- Canada launches Offshore Tax Informant Program (17 January 2014)
- New Dutch Decree on substance requirements enters into force (16 January 2014)
- Vietnam issues detailed guidance on APA process effective 5 February 2014 (16 January 2014)
- Spain publishes new Argentina-Spain Tax Treaty (16 January 2014)
- Guatemalan Congress approves amendments to tax laws (15 January 2014)
- Global Payroll: one year on and closer to reality? (12 February)
Is one global payroll system an achievable goal for global organizations? Or are country-specific or regionally focused models more practical? One year ago, we asked global payroll leaders in multinational organizations to share their views. Their sentiments suggested that while one universal system is a good idea in theory, it is probably not practical. One year later, we asked this question again to see if their opinions changed. An upcoming webcast will discuss the latest global payroll study results, including core challenges, best practices and more. Register here.
EY industry, service and issue publications
- Transforming the bank: regulation and strategy
- Global Regulatory Network Executive Briefing - US agencies agree on final Volcker Rule
Oil and Gas
Power and Utilities
- 5 Insights for executives - Most utility COOs are convinced their shared support services costs are sufficiently transparent
- DNA of the COO - A power and utilities sector perspective