28 March 2014
Americas Tax Center Weekly Roundup
Latest news — Americas
OECD issues discussion draft on tax challenges of the digital economy under BEPS Action 1
On 24 March 2014, the OECD released its BEPS discussion draft on the challenges that the spread of the digital economy poses for the application of existing international tax rules and detailed options to address those difficulties. Comments on the discussion draft are due 14 April 2014.
OECD releases discussion draft on preventing treaty abuse under BEPS Action 6 – EY Tax Alert now available
As we reported in last week’s Americas Tax Center Roundup, the OECD released on 14 March 2014 a discussion draft in connection with Action 6 on treaty abuse under its Action Plan on Base Erosion and Profit Shifting (BEPS). The document, titled BEPS Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, contains proposed tax treaty provisions and related commentary together with proposed domestic law provisions to address treaty shopping and other potential treaty abuse. A Tax Alert is now available.
Canadian nonresident trust rules require notice of relieving elections by 31 March or 25 June 2014
A nonresident trust to which these rules apply will be deemed to be resident in Canada for certain purposes and taxed on its worldwide income and gains. These rules may apply in many situations where there are both nonresident and Canadian-resident beneficiaries. A Tax Alert provides details.
Venezuela amends Master Law for Fair Prices – Tax Alert now available
An EY Tax Alert is now available on Venezuela’s amended Master Law of Fair Prices (Law) (Decree No.600 published in the Official Gazette No.40.340, of 24 January 2014) to increase price control faculties. The purpose of the law is to ensure the sound, fair, equitable, profitable and sovereign development of the national economy through the determination of fair prices for goods and services. On 7 February 2014, the National Superintendence for the Defense of Socio-Economic Rights (SUNDDE, for its acronym in Spanish) published an Administrative Order that set out the general accounting criteria for the determination of fair prices. A Tax Alert has details.
Peru's new tax treaties with Switzerland, Korea enter into force
The new Peru-Switzerland income tax treaty entered into force on 10 March 2014. The provisions of the convention will be effective on 1 January 2015 (see Tax Alert). In addition, the new Peru-Korea income tax treaty entered into force on 3 March 2014. Provisions of this treaty also will be effective 1 January 2015 (see Tax Alert).
Panama amends reporting requirements for monthly Purchase and Non-Taxpayer Reports
Panama recently eliminated the requirement for offshore companies with offices in Panama to file a monthly Purchase Report. The government has now amended the reporting requirements for specified legal entities and individuals. A Tax Alert provides details.
Canadian Saskatchewan and Yukon 2014–15 provincial budgets tabled
Saskatchewan Finance Minister Ken Krawetz tabled the Canadian province’s 2014-15 budget on 19 March 2014 in Regina. A Tax Alert has details. Also, Yukon Premier and Finance Minister Darrell Pasloski tabled the territory’s fiscal 2014–15 budget on 25 March 2014. A Tax Alert has details.
Latest issue of EY’s TradeWatch now available
The March 2014 issue of TradeWatch, a quarterly communication prepared by EY’s Global Trade practice, is now available. "Spotlight" articles in the latest issue discuss related party design and development costs in Canada and a US valuation ruling on exclusive distribution rights. The latest issue also covers a number of additional developments in Argentina, Brazil, Mexico and Puerto Rico.
This week's tax treaty news in the Americas
- Brazil and Israel: social security agreement signed
- Venezuela and Saudi Arabia: tax treaty authorized for signature by Saudi Arabia
This week's EY Global Tax Alerts
- Tax treaty between Peru and Switzerland enters into force ( 26 March 2014 )
- Tax treaty between Peru and Korea enters into force ( 26 March 2014 )
- Australia releases dividend washing integrity changes exposure draft legislation for comment ( 25 March 2014 )
- OECD releases discussion draft on preventing treaty abuse under BEPS Action 6 ( 24 March 2014 )
- Venezuela amends Master Law for Fair Prices ( 24 March 2014 )
- UK delivers Budget 2014 ( 21 March 2014 )
- Spain releases report on proposal to reform the Spanish tax system ( 21 March 2014 )
- Nigerian Tax Authorities issue transfer pricing guidance and forms ( 21 March 2014 )
- Nigerian Investment Promotion Commission releases Pioneer Status Incentive Regulations ( 21 March 2014 )
- China relaxes company registration formalities ( 20 March 2014 )
- Israeli High Court of Justice rejects petition to deny "foreign resident" VAT status from multinational internet companies ( 20 March 2014 )
- Securing taxable deductions for Chinese corporate income tax return purposes ( 20 March 2014 )
Recently archived webcasts now available on-demand
- Proposed and temporary regulations under FATCA: what they mean to your business
On 20 February 2014, the US IRS and Treasury released proposed and temporary regulations providing further guidance under the Foreign Account Tax Compliance Act (FATCA) and "conforming" requirements. A recent webcast discussed the impact of these provisions on both US withholding agents and foreign financial institutions. Watch it on-demand here.
- Chairman Camp’s comprehensive US tax reform proposal: what businesses need to know
US House Ways and Means Committee Chairman Dave Camp (R-MI) has released his long-anticipated tax reform proposal. The plan would reform the US corporate, individual and international tax regimes. A recent webcast discussed the Camp proposal and its effects on businesses. Watch it on-demand here.
EY industry, service and issue publications
Oil and Gas
Power and Utilities
- Ready for takeoff: Preparing for your journey into the cloud
- Mobile device security: Understanding vulnerabilities and managing risks
- Data loss prevention: keeping sensitive data out of the public domain
- Building confidence in IT programs
- A risk-based approach to segregation of duties