Global Tax Alert. Mexico s tax reform proposal significantly affects maquiladora industry. News from Americas Tax Center
|
|
- Lambert Hutchinson
- 6 years ago
- Views:
Transcription
1 11 September 2013 News from Americas Tax Center Americas Tax Center Ernst & Young s Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the region to help our clients address administrative, legislative and regulatory opportunities and challenges in the 33 countries that comprise the Americas region. Copy into your web browser: Services/Tax/Americas-Tax- Center---borderless-clientservice Mexico s tax reform proposal significantly affects maquiladora industry On 8 September 2013, Mexico s President Pena Nieto presented a major tax reform proposal (the Proposed Reform) to the Mexican Congress that significantly affects the maquiladora industry. The proposal must be debated and approved by the two houses of Congress by the end of October before becoming law (with an expected effective date of 1 January 2014). 1 As part of the modifications, the proposal includes significant changes to the maquiladora industry, including a new definition of what qualifies as maquiladora activities for income tax purposes and eliminates exemptions to the once beneficial value added tax treatment. Based on the preamble to the Proposed Reform, these proposed modifications are necessary: (1) to restrict the application of the tax benefits to the originally intended beneficiaries, (2) to avoid inequalities and disadvantages with respect to the Mexican domestic industry, and (3) to provide additional control and oversight mechanisms to the tax authorities with respect to the application of the tax benefits. Likewise, the preamble indicates that the elimination of a preferential tax regime is consistent with the OECD s recommendations. Finally, the Proposed Reform states that the economic considerations that justified the creation of the maquiladora regime are no longer present. Thus, these modifications attempt to return to the requirements that motivated the original design of the maquiladora regime (such as the exportation of all of its production). Moreover, this proposal would also allow for differentiating companies that benefit from the income tax benefits of this regime from those that only apply the customs benefits. The following section summarizes the main proposed modifications.
2 Income tax Permanent establishment Currently, the Mexican Income Tax Law (MITL) provides that foreign residents are entitled to a statutorily provided exemption from creating a permanent establishment (PE) in Mexico as a result of their economic or legal ties to maquiladoras, provided that the foreign parties are resident in a country with which Mexico has entered into a Tax Treaty and the maquiladora meets the transfer pricing guidelines provided in the MITL. It bears noting that this exemption is provided for those activities qualifying as maquiladora activities. The definition of maquiladora activities under Article 33 of the IMMEX (Mexico s maquiladora program) Decree was modified, effective 1 January This definition provides that, among others, at least 30% of the machinery and equipment used in the maquiladora operations should be owned by the foreign resident principal. The proposed reform incorporates a new definition of maquiladora activities in Article 175 of the new MITL. This new definition of maquiladora activities is very similar to the definition introduced under the modification to Article 33 of the IMMEX Decree. However, several important differences should be noted: Section I provides that the goods must be returned abroad without referencing the ability to use virtual exports to meet this requirement. Notably, Article 33 of the IMMEX Decree explicitly allows virtual exports in meeting the requirement of returning abroad a transformed good. Section II of the definition under Article 175 adds an export threshold of 90% of the Maquiladora s total annual invoicing. Notably, it does not clarify whether the export threshold could be met with virtual exports and/or indirect exports. Section IV provides that machinery and equipment must be owned by the foreign resident. However, unlike Article 33 of the IMMEX Decree, no reference is made to whether the maquiladora company may also own machinery and equipment. Likewise, Section IV of this new definition does not include the 30% minimum threshold for machinery and equipment owned by the foreign resident nor the grandfathering provisions to companies performing maquiladora operations through , which are currently provided under Article 33 of the IMMEX Decree. Finally, product development and quality improvement operations no longer qualify as maquiladora activities for purposes of applying the tax benefits. Moreover, the PE exemption for shelter maquiladoras is limited to three years. After such period, the foreign resident will be exposed to PE status in Mexico or will need to establish its manufacturing activities through its own subsidiary. Without the PE exemption, the determination of whether a PE exists should be made based on the facts and circumstances of the operations of the foreign resident in Mexico, under Mexican tax rules, as well as the applicable tax treaty. With elimination of the IETU 2 law, the 2007 Calderon Presidential Decree that expires on 31 December 2013 will not be renewed. Consequently, maquiladoras will no longer be eligible for a reduced effective tax rate of 17.5%. Maquiladoras would be subject to the normal corporate income tax rate of 30%. Likewise, considering that the 2003 Fox Presidential Decree references the old income tax law, the tax credit offered by the Fox Presidential Decree is presumably also eliminated. Transfer pricing Currently, Article 216-Bis of the MITL provides specific transfer pricing methodologies for companies operating under the maquiladora program. These transfer pricing methods may create a simplified transfer pricing compliance mechanism and may provide an ability to reach a more favorable transfer pricing result vis-à-vis Mexico s transfer pricing guidelines for non-maquiladora companies. 2
3 The existing available methods include: Transfer pricing study based on cost plus mark-up +1% of value of foreign owned M&E This method consists of determining an arm s-length cost plus mark-up and adding a value equal to 1% of the net book value of the foreignowned, fixed assets. Safe Harbor This method provides that the taxable income of the maquiladora should represent the greater of a 6.9% return on assets (ROA) calculation, including the value of foreign-owned fixed assets and inventory or a 6.5% markup on costs. In determining the cost base, all operating costs related to the maquiladora operation, including costs borne by the foreign related party, should be considered, except for a) inventory purchases made by the foreign related party, b) depreciation on foreign owned assets, c) costs borne by a foreign related party outside of Mexico, d) financial costs (e.g., interest and foreign exchange losses), and e) B-10 inflationary adjustments. Transfer pricing study based on ROA methodology This method consists of preparing a transfer pricing study in accordance with the transactional net margin method and applying an ROA profit level indicator. The ROA calculation must include foreign owned fixed assets (but excludes inventory). Additionally, the maquiladora may elect to file for an advanced pricing agreement (APA) if it wishes to obtain certainty regarding its transfer pricing policies. The Proposed Reform modifies the transfer pricing methods available for the maquiladoras to eliminate the transfer pricing alternatives. Thus, maquiladoras may only apply the Safe Harbor methodology or pursue an APA. The new rules under the Proposed Reform resemble the transfer pricing rules available to maquiladoras prior to Value Added Tax (VAT) Under existing rules, maquiladoras are entitled to several benefits regarding VAT, including: No import VAT as a result of conducting a temporary importation. A 0% VAT rate applies on the maquiladora services fee invoiced to its related party (related to export production). Certain sales of goods that are physically located in Mexico and imported temporarily are exempt from VAT. This exemption includes sales between non-mexican companies, as well as certain sales between non-mexican companies and maquiladoras. When a maquiladora purchases goods or services from certain Mexican suppliers, it has the option to withhold the applicable VAT on the purchase. Thus, the maquiladora is entitled to an immediate credit of the VAT, resulting in no net cash outflow related to the VAT. A non-mexican company may purchase goods from certain Mexican suppliers with a 0% VAT rate as long as the goods are physically delivered to the maquiladora s facility and the proper virtual pedimento (customs-related) filings are made. The maquiladora company may withhold VAT on purchases made to Mexican suppliers. This withholding mechanism minimizes cash flow implications for the maquiladora. The proposed reform eliminates some of these beneficial VAT rules, as follows: Temporary importations will now be subject to VAT at the general rate of 16% (including those made in the border region and through virtual pedimentos) with allowed credit or refund once the goods are returned abroad. That is, temporary importations are no longer exempt from VAT and the recovery of the VAT paid may take significant time and effort. Companies must carefully evaluate the cash flow implications arising from this proposal. The VAT exemption on sales of temporarily imported products between non-mexican parties or from non-mexican residents to 3
4 maquiladoras is eliminated. Such sales may be subject to VAT also at the rate of 16%, which will only be recoverable if the purchaser is a VAT taxpayer in Mexico, otherwise the VAT will become an additional cost. It is worth mentioning that these two proposals will directly affect supply chain structures, as each virtual importation made along the chain will be subject to VAT and each sale made by non- Mexican residents in connection with such transfers will also be subject to VAT because the goods are being sold within Mexico. Finally, the option to withhold VAT on purchases of goods or services from certain Mexican suppliers is eliminated. In summary, if the proposed changes are approved by Congress, companies currently benefitting from the maquiladora regime will have to carefully evaluate the effect that the proposed reform would have on their existing operations. Endnotes 1. See EY, Mexico s President presents tax reform proposal to Congress, dated 9 September 2013, for further information on the full tax reform proposal. 2. IETU (Impuesto Empresarial a Tasa Unica) is generally referred to as Mexico s Flat Rate Business Tax. 4
5 For additional information with respect to this Alert, please contact the following: Mancera, S.C., International Tax Services, Mexico City Manuel Solano Koen van t Hek koen.van-t-hek@mx.ey.com Mancera, S.C., Latin American Business Center, Mexico City Terri Grosselin terri.grosselin@ey.com Ernst & Young LLP, Latin American Business Center, New York Alfredo Alvarez alfredo.alvarez@ey.com Alejandra Sanchez de la Garza alejandra.sanchezdelagarza@ey.com Ernst & Young LLP, Latin American Business Center, Dallas Michael Becka michael.becka@ey.com Ernst & Young LLP, Latin American Business Center, San Diego Ernesto Ocampo ernesto.ocampo@ey.com Co-Directors of America s Tax Center Global Tax, Eric Solomon, Washington, DC Global Tax, Michael Mundaca, Washington, DC America s Tax Center Chief Operating Officer Declan Gavin, Washington, DC ATC - Customs William Methenitis, Dallas ATC - Global Compliance and Reporting (GCR) Ken Brown, Dallas ATC - Global Tax Desks Gerrit Groen, New York ATC - Tax Controversy Rob Hanson (interim), Washington, DC ATC - Tax Effective Supply Chain Management (TESCM) Lisa Lim, New York ATC - Tax Performance Advisory (TPA) Gary Paice, Chicago ATC - Tax Policy Michael Mundaca (interim), Santiago, Chile ATC - Value Added Tax (VAT) Jean-Hugues Chabot, Montreal, Canada ATC - Insurance Terry Jacobs, Washington, DC 5
6 EY Assurance Tax Transactions Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com. Americas Tax Center 2013 EYGM Limited. All Rights Reserved. EYG No. CM3796 This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. Please refer to your advisors for specific advice. ey.com
Global Tax Alert. Mexico s revised tax reform proposal includes changes affecting the maquiladora industry. Income tax. News from Americas Tax Center
25 October 2013 News from Americas Tax Center Americas Tax Center EY s Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the region to help our
More informationGlobal Tax Alert. Mexico s President issues Decree granting tax incentives to maquiladoras. Executive summary. News from Americas Tax Center
30 December 2013 News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the region to help
More informationGlobal Tax Alert. Mexico s lower House of Congress approves tax reform proposal affecting financial institutions. Allowance for loan losses
24 October 2013 News from Americas Tax Center and Financial Services Americas Tax Center EY s Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across
More informationGlobal Tax Alert. Mexico s President submits secondary legislation to Congress related to the energy reform. Background.
5 May 2014 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the region
More informationGlobal Tax Alert. Colombia issues regulations on taxation of permanent establishments. Permanent establishment definition. Fixed place of business
8 January 2014 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the
More informationGlobal Tax Alert. Honduras adopts tax reform. Fines, surcharges and interest. Alternate minimum income tax 1
28 January 2014 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across
More informationGlobal Tax Alert. Colombia s Central Bank modifies Exchange Regime regulations as well as some forms and exchange declarations
7 August 2013 News from Americas Tax Center Americas Tax Center Ernst & Young s Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the region to
More informationGlobal Tax Alert. Puerto Rico s Governor signs act affecting audited financial statements requirement. Effective date
23 January 2014 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across
More informationMexican Tax Authorities publish format for filing 2014 DIEMSE
26 February 2016 Global Tax Alert News from Americas Tax Center Mexican Tax Authorities publish format for filing 2014 DIEMSE EY Global Tax Alert Library The EY Americas Tax Center brings together the
More informationUS taxpayers seeking unilateral APAs with Mexico for maquiladoras will not be subject to double taxation as long as certain requirements are met
20 October 2016 International Tax Alert News from Transfer Pricing US taxpayers seeking unilateral APAs with Mexico for maquiladoras will not be subject to double taxation as long as certain requirements
More informationNew Protocol to Mexico-Spain Treaty to enter into force
24 July 2017 Global Tax Alert News from Americas Tax Center New Protocol to Mexico-Spain Treaty to enter into force EY Global Tax Alert Library The EY Americas Tax Center brings together the experience
More informationGlobal Tax Alert. Puerto Rico s legislature proposes numerous tax changes for individuals, conduit entities and corporations.
3 March 2015 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the
More informationDominican Republic modifies transfer pricing regulations
4 April 2014 Global Tax Alert News from Transfer Pricing and Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals
More informationIRS rules consent fee paid on contingent payment debt instrument may result in a taxable exchange
13 August 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationTreasury and IRS finalize regulations under Section 909 foreign tax credit splitting events
13 February 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationTreasury and IRS plan to change rules for claiming refunds and credits for certain withholding taxes
4 May 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationMexico modifies transfer pricing deadlines for filers of DISIF
16 February 2018 Global Tax Alert News from Americas Tax Center and Transfer Pricing Mexico modifies transfer pricing deadlines for filers of DISIF EY Global Tax Alert Library The EY Americas Tax Center
More informationSpain proposes to strengthen CFC rules
5 November 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date Spain
More informationGlobal Tax Alert. Singapore Tax Authority releases updated transfer pricing guidelines. Executive summary. News from Transfer Pricing
8 January 2015 Global Tax Alert News from Transfer Pricing EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/
More informationGlobal Tax Alert. Colombian Government proposes tax reform. Proposed tax changes. News from Americas Tax Center
7 October 2014 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the
More informationGlobal Tax Alert News from Americas Tax Center Chile s Ministry of Finance presents amendments to tax reform
20 August 2014 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the
More informationJapan and Chile sign income tax treaty
28 January 2016 Global Tax Alert Japan and Chile sign income tax treaty EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: www.ey.com/taxalerts
More informationGlobal Tax Alert. Canada Alberta increases corporate and personal income tax rates. Executive summary. Detailed discussion
22 June 2015 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the
More informationCanada: Québec announces QST and e-commerce measures
5 April 2018 Indirect Tax Alert News from Americas Tax Center Canada: Québec announces QST and e-commerce measures EY Global Tax Alert Library The EY Americas Tax Center brings together the experience
More informationAustralian Treasury releases revised Exposure Draft on Investment Manager exemption
23 March 2015 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date Australian
More informationOECD launches International Compliance Assurance Programme pilot
26 January 2018 Global Tax Alert OECD launches International Compliance Assurance Programme pilot EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into
More informationInternational Tax Alert
30 April 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationGuinea (Conakry) enacts new Petroleum Code
27 March 2015 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date Guinea
More informationTreasury and IRS issues guidance on 2% tax on payments US government makes to foreign persons under certain contracts
27 April 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationOECD releases 2013 Mutual Agreement Procedure statistics
2 December 2014 Global Tax Alert News from Transfer Pricing and Controversy EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/
More informationBarbados conducting review on OECD-designated preferential regimes
26 October 2017 Global Tax Alert News from Americas Tax Center Barbados conducting review on OECD-designated preferential regimes EY Global Tax Alert Library The EY Americas Tax Center brings together
More informationExecutive summary. Detailed discussion. EY Global Tax Alert Library
22 December 2016 International Tax Alert US final regulations retroactively eliminate Section 367(d) s exception for foreign goodwill and going concern value and narrow Section 367(a) s active trade or
More informationIRS issues instructions to Form W-8BEN-E
30 June 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationSouth African Revenue Service releases public notice on recordkeeping for transfer pricing transactions
9 November 2016 Global Tax Alert News from Transfer Pricing South African Revenue Service releases public notice on recordkeeping for transfer pricing transactions EY Global Tax Alert Library Access both
More informationOECD releases the United States peer review report on implementation of BEPS Action 14 minimum standards
2 October 2017 Global Tax Alert OECD releases the United States peer review report on implementation of BEPS Action 14 minimum standards EY Global Tax Alert Library Access both online and pdf versions
More informationOECD, UN, IMF and World Bank issue toolkit for addressing difficulties in accessing comparable data for transfer pricing analysis
6 July 2017 Global Tax Alert OECD, UN, IMF and World Bank issue toolkit for addressing difficulties in accessing comparable data for transfer pricing analysis EY Global Tax Alert Library Access both online
More informationHong Kong and India sign income tax treaty
28 March 2018 Global Tax Alert Hong Kong and India sign income tax treaty EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: www.ey.com/taxalerts
More informationOECD releases new guidance on transfer pricing for low value-adding intra-group services under BEPS Actions 8-10
13 October 2015 EY OECD BEPS project Stay up-to-date on OECD s project on Base Erosion and Profit Shifting with EY s online site containing a comprehensive collection of resources, including news, Alerts
More informationUS Section 871(m) final and temporary regulations address dividend equivalents
30 January 2017 International Tax Alert US Section 871(m) final and temporary regulations address dividend equivalents EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax
More informationGlobal Tax Alert. OECD releases report under BEPS Action 2 on hybrid mismatch arrangements. Executive summary
23 September 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date
More informationBelgium introduces 100% participation exemption
20 March 2018 Global Tax Alert Belgium introduces 100% participation exemption EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: www.ey.com/taxalerts
More informationIRS issues final, temporary and proposed regulations on determining PFIC ownership and annual filing requirements for PFIC shareholders
10 January 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationIRS issues guidance on treatment under Sections 482 and 901 of transactions with foreign branches or disregarded entities
12 December 2013 International Tax Alert News from Transfer Pricing EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/
More informationUS regulations forthcoming on partnership nonrecognition of property contributions
19 August 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationOECD releases interim report on the tax challenges arising from digitalization
16 March 2018 Global Tax Alert OECD releases interim report on the tax challenges arising from digitalization EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts.
More informationSpain to require maintenance and submission of VAT books by electronic means
24 November 2015 Indirect Tax Alert Spain to require maintenance and submission of VAT books by electronic means EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts.
More informationSpain to require electronic records and submission for VAT books starting July 2017
12 December 2016 Indirect Tax Alert Spain to require electronic records and submission for VAT books starting July 2017 EY Global Tax Alert Library Access both online and pdf versions of all EY Global
More informationUS Senator Levin introduces bill to tighten inversion rules under Section 7874
2 June 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationGlobal Tax Alert. Spain proposes amendments to the Spanish ETVE and participation exemption regimes. Executive summary. Detailed discussion
12 September 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date
More informationGlobal Tax Alert. Spain releases second draft bill amending Spanish tax system. Executive summary. Detailed discussion
7 August 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date Spain
More informationUS IRS releases proposed Qualified Intermediary Agreement
7 July 2016 International Tax Alert US IRS releases proposed Qualified Intermediary Agreement EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your
More informationUS IRS and Treasury issue guidance offering RICs with Section 853 elections alternative methods for handling foreign tax refunds
22 January 2016 International Tax Alert US IRS and Treasury issue guidance offering RICs with Section 853 elections alternative methods for handling foreign tax refunds EY Global Tax Alert Library Access
More informationUnited States and Vietnam sign first income tax treaty
15 July 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationGlobal Tax Alert. Spain releases draft bill of Spanish tax system reform. Executive summary. Detailed discussion
25 June 2014 Spain releases draft bill of Spanish tax system reform EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationHong Kong releases new practice note on concessionary tax regime for qualifying aircraft leasing activities
10 November 2017 Global Tax Alert Hong Kong releases new practice note on concessionary tax regime for qualifying aircraft leasing activities EY Global Tax Alert Library Access both online and pdf versions
More informationCanada amends taxation of investment income earned through a private corporation
14 December 2015 Global Tax Alert News from Americas Tax Center Canada amends taxation of investment income earned through a private corporation EY Global Tax Alert Library The EY Americas Tax Center brings
More informationIRS rules on effect of Section 302(a) redemption on post E&P and foreign income tax pools
8 November 2013 International Tax Alert IRS rules on effect of Section 302(a) redemption on post- 1986 E&P and foreign income tax pools Executive summary On 30 September 2013, the Internal Revenue Service
More informationGlobal Tax Alert News from Americas Tax Center New Mexican fiscal system approved for the oil and gas industry
14 August 2014 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the
More informationGlobal Tax Alert. OECD releases report under BEPS Action 13 on Transfer Pricing Documentation and Country-by-Country Reporting.
23 September 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date
More informationChief Counsel Advice concludes that accrued but unpaid interest constitutes an obligation of a US person for purposes of Section 956
11 September 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationIRS issues instructions for requester of Forms W-8BEN, W-8BEN-E, W-8ECI, W-8EXP, and W-8IMY
28 July 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationIRS updates procedures for withholding foreign partnerships and withholding foreign trusts; coordinates rules with FATCA
15 August 2014 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationUS IRS and Treasury amend FIRPTA regulations to reflect PATH Act
23 February 2016 International Tax Alert US IRS and Treasury amend FIRPTA regulations to reflect PATH Act EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy
More informationUK s bilateral APA program for financial transactions is in line with growing global approach
5 November 2018 Global Tax Alert News from Transfer Pricing UK s bilateral APA program for financial transactions is in line with growing global approach NEW! EY Tax News Update: Global Edition EY s new
More informationGlobal Tax Alert. Costa Rican Government submits to Congress two bills to replace the Income Tax Law and substitute the current Sales Tax Law with VAT
26 August 2015 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the
More informationRussia implements tax law changes in 2016
26 January 2016 Global Tax Alert Russia implements tax law changes in 2016 EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: www.ey.com/taxalerts
More informationIndia introduces secondary adjustment and interest limitation rules
6 April 2017 Global Tax Alert News from Transfer Pricing India introduces secondary adjustment and interest limitation rules EY Global Tax Alert Library Access both online and pdf versions of all EY Global
More informationItaly issues additional clarifications on Patent Box regime
8 April 2016 Global Tax Alert Italy issues additional clarifications on Patent Box regime EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web
More informationGlobal Tax Alert. Venezuela amends additional laws through Enabling Act 1. Law on Exchange Regime and Illegal Acts. News from Americas Tax Center
15 January 2015 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across
More informationCanada: Ontario unveils details of retirement pension plan
15 February 2016 Global Tax Alert News from Americas Tax Center Canada: Ontario unveils details of retirement pension plan EY Global Tax Alert Library The EY Americas Tax Center brings together the experience
More informationIRS applies Section 904(f) recapture exception to intercompany asset transfer preceding deconsolidation of transferee member
12 January 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationUpdated Decrees confirm Dutch APA/ATR procedures and practice
16 June 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date Updated
More informationUK HMRC issues update on diverted profits tax
20 March 2015 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date UK
More informationOECD meets with business on base erosion and profit shifting action plan
4 October 2013 OECD meets with business on base erosion and profit shifting action plan Executive summary On 1 October 2013, the Organisation for Economic Cooperation and Development (OECD) held a meeting
More informationOECD releases final report on preventing the artificial avoidance of permanent establishment status under Action 7
19 October 2015 Global Tax Alert EY OECD BEPS project Stay up-to-date on OECD s project on Base Erosion and Profit Shifting with EY s online site containing a comprehensive collection of resources, including
More informationSpain enacts tax reform
4 December 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date Spain
More informationGlobal Tax Alert. OECD releases final report on Hybrid Mismatch Arrangements under Action 2. Executive summary
11 October 2015 Global Tax Alert EY OECD BEPS project Stay up-to-date on OECD s project on Base Erosion and Profit Shifting with EY s online site containing a comprehensive collection of resources, including
More informationCanada: Quebec relaxes QST ITR restrictions
31 October 2017 Indirect Tax Alert News from Americas Tax Center Canada: Quebec relaxes QST ITR restrictions EY Global Tax Alert Library The EY Americas Tax Center brings together the experience and perspectives
More informationCanada: Ontario Ministry of Finance seeks input on proposals to facilitate compliance with the Land Transfer Tax Act
24 July 2017 Indirect Tax Alert News from Americas Tax Center Canada: Ontario Ministry of Finance seeks input on proposals to facilitate compliance with the Land Transfer Tax Act EY Global Tax Alert Library
More informationTurkey amends transfer pricing legislation
19 August 2016 Global Tax Alert News from Transfer Pricing Turkey amends transfer pricing legislation EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into
More informationIreland s Country-by- Country reporting notification deadline is 31 December 2016
12 December 2016 Global Tax Alert News from Transfer Pricing Ireland s Country-by- Country reporting notification deadline is 31 December 2016 EY Global Tax Alert Library Access both online and pdf versions
More informationHong Kong-India income tax treaty enters into force
6 December 2018 Global Tax Alert Hong Kong-India income tax treaty enters into force NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email subscription
More informationEU Commission approves enhancements to Madeira International Business Center Tax Regime
3 September 2013 EU Commission approves enhancements to Madeira International Business Center Tax Regime Executive summary On 2 July 2013, the EU Commission issued a decision allowing Portugal to increase
More informationUS IRS and Treasury issue proposed and temporary regulations under FATCA, as well as conforming regulations
25 February 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date
More informationGermany- Philippines revised income tax treaty enters into force
4 March 2016 Global Tax Alert Germany- Philippines revised income tax treaty enters into force EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your
More informationUS IRS limits use of mandatory transfer pricing IDR and instructs examiners on penalties in transfer pricing cases
24 January 2018 Global Tax Alert News from Transfer Pricing US IRS limits use of mandatory transfer pricing IDR and instructs examiners on penalties in transfer pricing cases EY Global Tax Alert Library
More informationIndian tax authorities impose minimum alternate tax on foreign portfolio investors
29 April 2015 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date Indian
More informationUruguay s Ministry of Economy formally proposes tax increases
25 July 2016 Global Tax Alert News from Americas Tax Center Uruguay s Ministry of Economy formally proposes tax increases EY Global Tax Alert Library The EY Americas Tax Center brings together the experience
More informationCouncil of the EU reaches an agreement on new mandatory transparency rules for intermediaries and taxpayers
14 March 2018 Global Tax Alert Council of the EU reaches an agreement on new mandatory transparency rules for intermediaries and taxpayers EY Global Tax Alert Library Access both online and pdf versions
More informationItalian Tax Authorities rule under Advance Ruling for New Investments that logistics hub for auxiliary activities does not create PE
14 February 2017 Global Tax Alert Italian Tax Authorities rule under Advance Ruling for New Investments that logistics hub for auxiliary activities does not create PE EY Global Tax Alert Library Access
More informationInternational Tax Alert. Executive summary
19 May 2015 International Tax Alert EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationGlobal Tax Alert. Canada s Department of Finance releases draft financial services tax measures. Executive summary. Detailed discussion
4 September 2014 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across
More informationIRS issues annual APA report for 2013
31 March 2014 International Tax Alert News from Transfer Pricing EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/
More informationIreland publishes Independent Review of Irish Corporate Tax Code
14 September 2017 Global Tax Alert Ireland publishes Independent Review of Irish Corporate Tax Code EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into
More informationRussian Finance Ministry communications clarify imposition of withholding tax on international transportation services
5 March 2018 Global Tax Alert Russian Finance Ministry communications clarify imposition of withholding tax on international transportation services EY Global Tax Alert Library Access both online and pdf
More informationIndirect Tax Alert. EU VAT refunds for non-eu businesses require action by 30 June Executive summary
3 June 2014 EU VAT refunds for non-eu businesses require action by 30 June 2014 Executive summary Non-EU businesses that have incurred VAT in Europe in 2013 may be able to recover VAT by applying to the
More informationItaly issues new laws with important transfer pricing and VAT implications
3 January 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date Italy
More informationBéndiksenLaw* Members of Law Offices International
Clients Bulletin Maquiladora Tax Regime Under the 2014 Tax Reform On December 11, 2013 a new Income Tax Law (the New Law ) as well as amendments to the Value Added Tax Law and other tax laws were published
More informationCanada: New Brunswick issues transitional rules regarding HST increase of 2%
6 April 2016 Indirect Tax Alert Canada: New Brunswick issues transitional rules regarding HST increase of 2% EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts.
More informationGlobal Tax Alert. Australian multinational antiavoidance. reporting and increased penalties. Wide-ranging impact requires action by multinationals
17 September 2015 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date
More information