Why Legal Entity Management Matters IV
|
|
- Darren Cook
- 5 years ago
- Views:
Transcription
1 Why Legal Entity Management Matters IV Collating and reporting legal entity information in today s environment: are you prepared? Issue 4.0 Q Collating and reporting legal entity information in today s environment: are you prepared? This report summarizes the themes and discussion points arising from EY s fourth Why Legal Entity Management Matters webcast held on 24 June The session was attended by participants from major corporates operating in a broad range of sectors. The webcast addressed a number of key developments and drivers that are focusing the spotlight on the need for the collation and reporting of information about legal entities. In particular, the panel discussed a number of the challenges and implications arising from the country-by-country reporting (CbCR) requirements of the Organisation for Economic Co-operation and Development s (OECD) Base Erosion and Profit Shifting (BEPS) Action 13, intercompany transactions and dealing with information gaps, along with the steps companies will need to take in response.
2 Polling question 1 For which of the following reasons does your organization actively collate and maintain legal entity data across your footprint? Please select all that apply. 17% Transparency reports, as applicable Financial statutory reporting or tax compliance Fulfil know your client requests Insurance cover Monitoring legal entities to keep optimum structures All of the above Other Source: webcast polling question data. 50% 42% 42% 0% 0% As the answers to polling question one show, organizations already cite a number of different, and overlapping, motivations for collating and maintaining legal entity data. The introduction of Action 13 will certainly add to them. 8% BEPS and CbCR: are you ready? The OECD s BEPS initiative aims to address governments concerns about aggressive tax avoidance. In particular, Action 13 will increase transparency by providing tax authorities with information that will enable them to determine whether groups have used their international structures for either base eroding or artificially shifting profits from one entity to another via transfer pricing activities, with the express purpose of minimizing tax. Action13 requires groups to use consistent templates for gathering information. There are three tiers of information: a master file, a local file and a country-by-county (CbC) report. These three are intended to be complementary, and it s likely that tax authorities will refer to all of them to review returns and undertake audits. Making sure that the information they include is consistent is therefore critical. To date, Spain has implemented CbCR, while implementation is in progress in Australia, Poland and the UK. Although no legislative proposal has been put forward yet, the Netherlands and South Africa have indicated they will have CbCR legislation implemented as per 1 January Worldwide adoption is expected by 2017 to cover 2016 information relating to the global allocation of the group s income, the jurisdictions where taxes are paid, and certain indicators of the location of economic activity within the group. Such indicators may be, for example, the location of research and development, manufacturing and production, or from where internal group finance is provided. Groups with a worldwide turnover that is less than 750 million will be exempt from CbCR, while all others will need to comply. What information is the OECD looking for? The CbC report requires an aggregation of country data, rather than a detailed account of each entity. However, in order to create the aggregation, it s likely that groups will need to look into the underlying entities. Information can be from a variety of sources, for example from the parent company s GAAP reporting of local subsidiaries, but it should be presented consistently for each year. So, in practice, in the event that a group changes its reporting standard (from GAAP to IFRS, for instance), it s likely that groups will need to explain the reason for change and make sure that in future years the reporting standard remains the same. 2 Why Legal Entity Management Matters IV
3 Traps for the unwary: could you stumble? While the requirements for CbCR may at first sight appear relatively straightforward, there are a number of issues that will require careful consideration in advance. For example, the categorization of tax jurisdiction could raise questions from the tax authorities about nonresident entities, depending on how they are treated in the report. Reporting on revenues could also be more complex than it first appears, as the guidance defines revenue as more than just sales and turnover: it also includes income streams such as royalties, interest and services. It s important, therefore, to understand exactly what the data represents before it is submitted to the tax authorities. Groups will have to report on the constituent entities resident in each tax jurisdiction. Although not the exact definition, a constituent entity is basically any unit that is included in the financial statements of the group, even if these are only for management reporting. Each unit s main business activity (or activities) needs to be identified, and this can be according to a predefined list or may be self-defined. Again, the information provided must be consistent with the descriptions given in the master file. Overall, complying with the requirements of Action 13 involves far more than simply populating a template. Groups will need to assess the entities that need to be included carefully, ensure that data comes from properly verified sources, in the correct format, is auditable and is disclosed consistently across the master file, local file and country reports. Therefore, making sure that there is a robust system in place for managing the legal entity data is going to be more important than ever. Companies that have already established a sound legal entity management (LEM) program will have a distinct advantage over those that have not. But even where there is a system in place, it is still likely that additional work will be required, in order to meet the requirements of CbCR. A platform for LEM action and how to build it For those companies that have yet to develop a program, the introduction of Action 13 creates a new incentive to act. While many are aware of the benefits of LEM, some companies have not perceived it as a priority. Action 13 and the deadline it imposes should change that perception. Creating a program will not only address compliance with CbCR, but also enables a central repository of legal entity information to be built. In time, this will enhance corporate governance and support decision-making, for instance on the effectiveness of the group structure, including better facilitation of legal entity restructuring and rationalization. Given the importance of ensuring compliance with BEPS and the myriad benefits associated with an effective LEM program, all companies should make sure that they put a system in place sooner, rather than later. Gathering the required information will, depending on each group s specific context, mean working with tax, legal, finance and HR. Understanding who owns the data, how to access it and maintain it is no small undertaking. The time to start is now. In EY s view, there are five key steps that all companies should think about when developing an LEM program: 1. Identify what is driving the LEM program, as this will, to a large extent, shape the data required. Understanding where the data is may not be straightforward, particularly where there may be more than, say, 20 jurisdictions in scope. 2. Diagnose the quality of the data available. Steps to remediate the data quality need to be completed before it can be used. For significant volumes of data this can be a relatively timeconsuming process, so it s important to get started well in advance of the deadline for CbCR. 3. Design the IT system that will meet the necessary requirements going forward. One key element of the design will be the reporting capabilities. Various functions will often want to see the same data in different formats that best suit their purposes. For example, tax may want to see legal entity data as an organization chart while finance would prefer it as an Excel file that they are able to work with. The right LEM system should be able to support all these diverse requirements. 4. Deliver and 5. Sustain the LEM program with well defined and implemented processes to ensure that data integrity is maintained going forward, and that a governance model is in place to ensure policies and processes are followed. Why Legal Entity Management Matters IV 3
4 Polling question 2 How does your organization collate and store legal entity data today? Please select all that apply. 33% 67% 33% 24% 29% Distributable reserves and intercompany balances Other issues that have come to prominence recently, and also highlight the challenges in finding the right information about legal entities, are distributable reserves and reliable intercompany balance data. They are an increasingly important topic in UK boardrooms because both regulators and investors want to know more about their management and disclosure. Some investors have raised their concerns about the lack of disclosure of reserves, and these issues can, very rapidly and publicly, undermine shareholder confidence in management and boards. Having access to a complete and accurate picture of reserves is therefore increasingly important. Polling question 3 How many of you have identified a need to tidy up, or rationalize, intercompany balances in your group? Please select one. 0% 32 Total Votes Central financial management database Central legal or company secretarial database Central tax compliance database Local databases or spreadsheets Outsourced LEM This is not applicable (or we do not know) 3% 9% 16% Source: webcast polling question data. 72% The answers to polling question 2 indicate the functions (legal, company secretarial, financial or tax) that tend to collect legal entity data today. But what the results highlight is the need to make sure that a cross-functional and more holistic approach is in place that can take into account the requirements of multiple users in the business for LEM data. Yes, we have considered it and are reviewing or will review intercompany balances as part of a project. Yes, we have considered it, but never seem to have the time and resources to address this need systematically. No, if there is a need to tidy up or rationalize, we address it on an ad-hoc basis. This is not applicable (or we do not know) Source: webcast polling question data. As responses to our third polling question highlight (see above), assessing intercompany positions is squarely on the radar of most organizations. Nearly three-quarters either currently review and rationalize intercompany balances or are planning to do so. 4 Why Legal Entity Management Matters IV
5 But achieving that picture is often made difficult by the sheer complexity of group structures. That complexity arises from both the number of legal entities and, critically, the relationships between them. These can include trading arrangements, financing structures or loan positions that can divert profits in such a way that makes them inaccessible or trapped. Intercompany positions can give rise to a number of challenges, and these tend to fall into four main areas: Transactions: excessive Intercompany balances can delay, or even in some cases prevent, a transaction completing, especially if the acquirer has concerns about the risks associated with the balances they will inherit. Operational: large intercompany balances can pose a risk of violating debt covenants. Furthermore, they can require additional financial and tax reporting, as well as situations whereby cash can be trapped if it used to settle interest payments, and there are insufficient reserves to flow the cash back around the group as required. Tax: here there can be additional tax cost and increased tax risk from holding Intercompany balances. Incremental tax costs can arise, for example, where interest is either not tax deductible, or is deductible at a lower tax rate than where the interest income is being taxed. From a tax risk perspective, where an arm s length interest rate is not charged on Intercompany balances, the key tax risk is around transfer pricing: this can present a one-sided tax cost to a group, with potential interest and penalties being levied in addition. Legal entity rationalization: stubborn Intercompany balances, for example those that may be subject to a tax risk, or where it is difficult to eliminate a balance because of the respective entity having insufficient reserves, can significantly increase the cost of a legal entity simplification. Each of these issues gives rise to material risks, and it s no surprise that many groups are now seeking to rationalize or eliminate their Intercompany balances. The tax environment, as typified by both the OECD s BEPS Action Plan and, more generally, an increased focused approach to transfer pricing by revenue authorities, is one driver for groups to consider their Intercompany positions. Other drivers include a buoyant M&A market, which brings forward the need for companies to seek efficiencies from rationalizing their legal entity structure pre- and post- acquisition or divestiture. Rationalizing or eliminating intercompany balances may be seen as a relatively straightforward exercise. But, as ever, there are potential associated risks. It s easy, for example, to generate unwanted tax costs if the approach to elimination does not carefully consider, and plan for, the risks in each relevant jurisdiction. It s essential to have a clear picture of distributable reserves, in order to understand what the impact of clearing up intercompany balances might be. Overall, it s very important to take a holistic view of all relevant issues. This requirement further emphasizes the need to maintain a tidy corporate structure through effective LEM. The more complex a structure is, the greater the likelihood that value will be lost when trading profits are converted into shareholder returns. Dealing with information gaps The implications of BEPS compliance and the challenges of intercompany balances both stress the importance of having comprehensive and detailed information about all the legal entities in a group structure. However, there are often substantial gaps. Problems with information gaps often arise in jurisdictions that lie outside core operations or have a semiautonomous relationship with the corporate headquarters (HQ). A relatively small entity in a particular jurisdiction may only have limited activities, yet the cost of maintaining the entity and rectifying information gaps for reporting may be higher than the group average, for example because of local bureaucratic intricacies. Why Legal Entity Management Matters IV 5
6 Therefore, in light of the BEPS initiatives, groups may want to eliminate any surplus legal entities to create a simpler structure that will save time and money on compliance and regulatory activity. Eliminating intercompany transactions can also generate significant savings of time and money. One project, for example, reduced the intercompany loan reconciliation process by an entire week following the elimination of 80 legal entities from a group of approximately 600. Information gaps can frequently be traced back to entities gained as part of an acquisition. We often recommend that clients considering, or making, an acquisition of another group should: 1. Negotiate to leave behind those legal entities that add no value or do not fit with the strategic objectives of the acquisition 2. Eliminate surplus entities immediately after acquisition to avoid the ongoing reporting and compliance obligations, as well as any risk that may attach to the corporate history of a legal entity Information gaps can have additional costs beyond remediation. Potential acquirers may ask for a discount to reflect the costs of cleaning up and managing reporting requirements. Or they may even walk away from a transaction. LEM: the time to act is now It s clear that a number of developments covered in the webcast are turning the spotlight on the need for clarity and firm control of legal entity data. Complex group structures and the relationships between entities create risks in the form of higher compliance costs, potentially adverse tax consequences and trapped profits. Falling foul of BEPS requirements could lead to reputational damage, as has already been seen in a number of high-profile cases. And in an increasingly active M&A market, being unable to explain or collate information on a legal entity adequately may depress the possible price on disposal, or could even mean a transaction does not proceed. Proactive and effective LEM is increasingly higher up the corporate agenda of internal and external stakeholders. Indeed, our latest Global Capital Confidence Barometer survey (April 2015) revealed that 54% of respondents, from a pool of senior executives, believe that the capital strategy for the forthcoming 12 months will focus on cost reduction and operational efficiency in the context of improving M&A activity (49%). Inevitably, any such strategic decisions will require the alignment of the legal entity structure to operations, while bearing in mind these regulatory challenges. In conclusion, those companies without a LEM program in place have no time to lose in remedying the situation. 6 Why Legal Entity Management Matters IV
7 Contacts Samantha Keen Partner Tel: Alistair Shaw Senior Manager Tel: Daniel Connell Director Tel: Russell Payne Director Tel: Jelger Buitelaar Director Tel: Richard Crisp Director Tel: Note: the contents of this document are intended to provide general explanations of legal entity elimination processes and related procedures. They do not constitute advice and are not instructions for carrying out these processes and procedures, and therefore should not be used as a guide to doing so. Professional advice should always be sought for these purposes. Why Legal Entity Management Matters IV 7
8 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 EYGM Limited. All Rights Reserved. EYG No. DE indd (UK) 11/15. Artwork by Creative Services Group Design. ED None In line with EY s commitment to minimize its impact on the environment, this document has been printed on paper with a high recycled content. 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
Why Legal Entity Management Matters
Q1 2014 Why Legal Entity Management Matters Issue 1.0 Global businesses are coming under pressure to simplify their legal entity structures. Country-by-country reporting (CbC) update Please note that since
More informationWhy Legal Entity Management matters Webcast 2014
Webcast 2014 6 March 2014 Your panel on today s webcast Samantha Keen Transaction Advisory Services Email: skeen@uk.ey.com Graham Roberts Financial Accounting Advisory Services Email: groberts1@uk.ey.com
More informationWhy Legal Entity Management Matters
Q1 2014 Why Legal Entity Management Matters Issue 1.0 Global businesses are coming under pressure to simplify their legal entity structures. Country-by-country reporting (CbC) update Please note that since
More informationPakistan implements formal transfer pricing documentation and Country-by- Country Reporting requirements
7 August 2017 Global Tax Alert News from Transfer Pricing Pakistan implements formal transfer pricing documentation and Country-by- Country Reporting requirements EY Global Tax Alert Library Access both
More informationThe BEPS project is the beginning, but is the end in sight?
The BEPS project is the beginning, but is the end in sight? Panel Moderator Panel Michael Hewson Annet Oguttu Oliver Wehnert Ryaad Owodally Africa Transfer Pricing Leader EY Africa Professor of Tax Law
More informationGlobal mining and metals tax survey. From backroom to boardroom. The CFO perspective at a glance
Global mining and metals tax survey From backroom to boardroom The CFO perspective at a glance The CFO perspective at a glance We want to help you get to the insight you need as quickly as possible. This
More informationManaging operational tax risk through technology
Managing operational tax risk through technology EY Africa Tax Conference September 2014 Panel Daryl Blakeway Director Tax Performance Advisory Leader EY South Africa Anthony Davis Director Tax Performance
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 informationEYGS UK tax strategy. Financial year ending 30 June 2017
EYGS UK tax strategy Financial year ending 30 June 2017 EY s values and our commitment to building a better working world drive our tax strategy Scope This tax strategy applies to EYGS LLP and all its
More informationRecord to report. Are you audit ready?
Record to report Are you audit ready? Panel Moderator Panel Cleedon Botha Anselme Patipewe Njiakin Stephen Ntsoane EY South Africa Director EY Cameroon Associate Director EY South Africa Director Sean
More informationSignificant tax changes: UK implications for captive insurers
Tax Services Significant tax changes: UK implications for captive insurers Executive summary This alert sets out how recent developments in the global tax environment may impact UK-connected groups with
More informationIntercompany financing facing new challenges. EY Africa Tax Conference September 2014
Intercompany financing facing new challenges EY Africa Tax Conference September 2014 Panel Moderator Ide Louw International Tax EY South Africa Panel Joseph Pagop Noupoue EY Jemimah Mugo EY Kenya Michael
More informationAudit Committee Bulletin
Issue 9 June 2015 Audit Committee Bulletin This bulletin reflects some of the issues that audit committee chairs of leading European companies are currently discussing with their advisors in EY. Foreword
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 informationJapan releases guidance on transfer pricing documentation requirements
7 June 2016 Global Tax Alert News from Transfer Pricing Japan releases guidance on transfer pricing documentation requirements EY Global Tax Alert Library Access both online and pdf versions of all EY
More informationReal estate funds. Are you leaving money on the table?
Real estate funds Are you leaving money on the table? Relevant to real estate fund managers or those managing investments under a segregated account mandate In a rapidly changing tax environment, it is
More informationTax authorities are going digital. Stay ahead and comply with confidence
Tax authorities are going digital Stay ahead and comply with confidence Digital tax administration: why is this happening now? Around the world, budget deficits are driving a need for new revenue sources.
More informationIssue 11 December Meeting the VAT e-audit challenge
Issue 11 December 2014 Meeting the VAT e-audit challenge Meeting the VAT e-audit challenge Themes and trends 01 We are living in a digital age. Technological advances in extracting and analyzing data are
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 informationIFRS adopted by the European Union
IFRS adopted by the European Union Status of the endorsement process for IFRS standards, interpretations and amendments issued by the IASB as at 31 December 2017 February 2018 1. Published International
More informationAustralia releases draft law implementing countryby-country. increasing penalties for tax avoidance and transfer pricing.
7 August 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 Australia
More informationBEPS Country-by-Country Reporting Rules and New Documentation Requirements
BEPS Country-by-Country Reporting Rules and New Documentation Requirements, EY LLP, Couzin Taylor LLP 67 th Annual Tax Conference 67e Conférence fiscale annuelle 2015 Agenda 1. The BEPS project: Action
More informationAustria publishes draft regulation for implementation of Transfer Pricing Documentation Law
3 June 2016 Global Tax Alert News from Transfer Pricing Austria publishes draft regulation for implementation of Transfer Pricing Documentation Law EY Global Tax Alert Library Access both online and pdf
More informationSingapore enacts transfer pricing documentation requirements and publishes updated transfer pricing guidelines
26 March 2018 Global Tax Alert News from Transfer Pricing Singapore enacts transfer pricing documentation requirements and publishes updated transfer pricing guidelines EY Global Tax Alert Library Access
More informationThe new global tax environment. What the global focus on Base Erosion and Profit Shifting (BEPS) means for your business
The new global tax environment What the global focus on Base Erosion and Profit Shifting (BEPS) means for your business Changing business environment Macroeconomic megatrends, mobility of capital and growth
More informationEgypt implements new transfer pricing guidelines
7 November 2018 Global Tax Alert News from Transfer Pricing Egypt implements new transfer pricing guidelines NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free,
More informationOECD BEPS final reports have implications for sovereign wealth and pension funds
14 January 2016 Global Tax Alert OECD BEPS final reports have implications for sovereign wealth and pension funds EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts.
More informationUK issues position paper update on corporate tax and the digital economy
14 March 2018 Global Tax Alert UK issues position paper update on corporate tax and the digital economy EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy
More informationIndian Tax Administration releases draft rules on Country-by-Country reporting and Master File implementation for public comment
10 October 2017 Global Tax Alert News from Transfer Pricing Indian Tax Administration releases draft rules on Country-by-Country reporting and Master File implementation for public comment EY Global Tax
More informationEU Council publishes updated Draft Directive on implementation of country-by-country reporting
23 March 2016 Global Tax Alert News from EU Tax Services EU Council publishes updated Draft Directive on implementation of country-by-country reporting EY Global Tax Alert Library Access both online and
More informationOECD updates its guidance on Country-by- Country Reporting
7 April 2017 Global Tax Alert OECD updates its guidance on Country-by- Country Reporting EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web
More informationExecutive summary Managing indirect tax controversy. Dealing with audits and disputes
Executive summary Managing indirect tax controversy Dealing with audits and disputes Executive summary VAT/GST and customs high on the tax agenda Knowing the indirect tax rules for your business operations
More informationIPO destination guide. Find the right market strategy to maximize value for your IPO or secondary listing
IPO destination guide Find the right market strategy to maximize value for your IPO or secondary listing IPO destination guide You ve decided to go public and now you need to map out all the necessary
More informationOECD releases discussion draft under BEPS Actions 8-10 on risk, recharacterization, and special measures
24 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
More informationUK publishes draft legislation on modified patent box regime
17 December 2015 Global Tax Alert UK publishes draft legislation on modified patent box regime EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your
More informationIPO destination guide. Find the right market strategy to maximize value for your IPO or secondary listing
IPO destination guide Find the right market strategy to maximize value for your IPO or secondary listing IPO destination guide You've decided to go public and now you need to map out all the necessary
More informationOn course for competitiveness. Budget survey 2014
On course for competitiveness Budget survey 2014 Executive summary With an election looming next year and EY s ITEM club predicting a modest upgrade to the short-term forecast for economic growth, the
More informationDutch Government launches internet consultation to amend the Dividend Withholding Tax Act
17 May 2017 Global Tax Alert Dutch Government launches internet consultation to amend the Dividend Withholding Tax Act EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax
More informationIndonesia implements new transfer pricing documentation requirements in line with BEPS Action 13
16 January 2017 Global Tax Alert News from Transfer Pricing Indonesia implements new transfer pricing documentation requirements in line with BEPS Action 13 EY Global Tax Alert Library Access both online
More informationThe UK s new corporate criminal offense. How adopting a robust risk-based approach could open the pathway for future global compliance
The UK s new corporate criminal offense How adopting a robust risk-based approach could open the pathway for future global compliance (CCO) of the failure to prevent the facilitation of tax evasion entered
More informationNew Zealand s incoming Government to prioritize International tax reforms
30 October 2017 Global Tax Alert New Zealand s incoming Government to prioritize International tax reforms EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy
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 informationAustralian Parliament passes Bill for MAAL, CbC reporting and increased penalties with wider ATO public reporting
4 December 2015 Global Tax Alert Australian Parliament passes Bill for MAAL, CbC reporting and increased penalties with wider ATO public reporting Private company tax data to be disclosed by ATO. Wide-ranging
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 informationWhat path will you navigate to carve-out sale success? Road map part 2: Sign to close
What path will you navigate to carve-out sale success? Road map part 2: Sign to close Congratulations; the deal is signed. Now another phase of heavy lifting begins. How do you successfully close your
More informationSouth African Revenue Service issues Country-by Country reporting, master file and local file guidance
26 June 2017 Global Tax Alert News from Transfer Pricing South African Revenue Service issues Country-by Country reporting, master file and local file guidance EY Global Tax Alert Library Access both online
More informationAlbanian Ministry of Finance issues instruction for implementation of new transfer pricing legislation
25 July 2014 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 informationCapital Confidence Barometer
May 2016 ey.com/ccb 14th edition highlights Capital Confidence Barometer Mexican companies maintain healthy pipelines and increase their focus on alliances to spur growth Key findings 36+64+M 50+50+M 36%
More informationAccounting for emission reductions and other incentive schemes
Accounting for emission reductions and other incentive schemes Introduction The impact of the global financial crisis has clearly been front-ofmind for most businesses in recent times. However, we are
More informationTransfer Pricing Alert
Transfer Pricing Alert July 2016 SAT issues highly significant new rules on related party transactions disclosure and contemporaneous transfer pricing documentation to update China s transfer pricing rules
More informationAIFMD: the road to implementation
AIFMD: the road to implementation Analysis of results September 2013 The survey: introduction There has been a lot of attention in recent months on the progress of managers toward the adoption of the
More informationApplying IFRS. IASB issues revised Conceptual Framework for Financial Reporting. April 2018
Applying IFRS IASB issues revised Conceptual Framework for Financial Reporting April 2018 Contents Overview 2 Status and purpose of the Conceptual Framework 3 Summary of the concepts 3 Chapter 1 The objective
More informationUS Tax Reform. Key provisions and their impacts on financial services companies. EMEIA Financial Services January 2018
US Tax Reform Key provisions and their impacts on financial services companies EMEIA Financial Services January 2018 Overview The US Tax Cuts and Jobs Act was passed at the end of 2017 and represents the
More informationAIFMD. State of the Union. November 2013
AIFMD State of the Union November 2013 So, here we are. The deadline has passed, the drop-dead date of 22 July 2014 is rapidly approaching, and many firms are asking: what has actually changed? The number
More informationInsurance Accounting Alert
Insurance Accounting Alert www.ey.com/insuranceifrs July 2014 What you need to know The IASB tentatively decided to confirm the principle for discount rates and provided additional application guidance
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 informationAll-in sustaining costs and all-in costs
All-in sustaining costs and all-in costs Tom Whelan, Global Mining & Metals Assurance Leader Americas Mining & Metals Forum September 2013 Background The World Gold Council (WGC) established a working
More informationInland Revenue Authority of Singapore releases 2016 Transfer Pricing Guidelines
11 January 2016 Global Tax Alert News from Transfer Pricing Inland Revenue Authority of Singapore releases 2016 Transfer Pricing Guidelines EY Global Tax Alert Library Access both online and pdf versions
More informationMeeting the challenges of the changing actuarial role. Actuarial Transformation in property-casualty insurers
Meeting the challenges of the changing actuarial role Actuarial Transformation in property-casualty insurers 1 As companies seek to drive profitable growth, both short term and long term, increasing the
More informationTransfer Pricing Alert
Transfer Pricing Alert EY Han Young newsletter July 2016 Transfer Pricing Current issue. Republic of Korea, United Kingdom, Belgium 2 Republic of Korea Korean Government Signed Multilateral Competent Authority
More informationEY Han Young newsletter May Transfer Pricing Alert
EY Han Young newsletter May 2015 Transfer Pricing Alert Transfer Pricing Current issue. CHINA / TAIWAN / EUROPEAN UNION / POLAND Transfer Pricing Alert May2015 2 CHINA China issues transfer pricing rules
More informationTax governance high on IRD s agenda. The 2015/16 Compliance Focus for Multinationals emphasises the role of good tax governance in mitigating tax risk
B 18 November 2016 Regular commentary from our experts on topical tax issues Issue 1 The 2015/16 Compliance Focus for Multinationals emphasises the role of good tax governance in mitigating tax risk All
More informationIndian Tax Administration releases final rules on Country-by-Country reporting and Master File implementation
6 November 2017 Global Tax Alert News from Transfer Pricing Indian Tax Administration releases final rules on Country-by-Country reporting and Master File implementation EY Global Tax Alert Library Access
More informationFinancial reporting guide
Financial reporting guide An overview of the New Zealand financial reporting framework January 2017 New Zealand financial reporting framework In 2016, New Zealand completed its transition to a new financial
More informationSouth African inbound services update
16 July 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 South
More informationOECD invites comments on discussion draft on treaty residence of pension funds
4 March 2016 Global Tax Alert OECD invites comments on discussion draft on treaty residence of pension funds EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts.
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 informationIRAS release of e-tax guide: Transfer Pricing Guidelines (Fourth edition)
Issue 9 17 January 2017 Transfer pricing alert IRAS release of e-tax guide: Transfer Pricing Guidelines (Fourth edition) Overview On 12 January 2017, the Inland Revenue Authority of Singapore (IRAS) released
More informationThe shape of things to come. Tax Director aspirations for the Business Tax Roadmap
The shape of things to come Tax Director aspirations for the Business Tax Roadmap Highlights In February 2016, we surveyed Tax Directors to understand the challenges they would like to see addressed in
More informationLuxembourg transfer pricing legislation at a glance
2017 EY TAX Alert Luxembourg Luxembourg transfer pricing legislation at a glance Executive summary The law of 23 December 2016 on the budget for the year 2017 ( Budget Law ) has introduced a new article
More informationCyprus Tax Authority issues guidance on revised transfer pricing framework for intra-group financing activities
5 July 2017 Global Tax Alert News from Transfer Pricing Cyprus Tax Authority issues guidance on revised transfer pricing framework for intra-group financing activities EY Global Tax Alert Library Access
More informationApplying IFRS. ITG discusses IFRS 9 impairment issues at December 2015 ITG meeting. December 2015
Applying IFRS ITG discusses IFRS 9 impairment issues at December 2015 ITG meeting December 2015 Contents Introduction... 3 Paper 1 - Incorporation of forward-looking information... 4 Paper 2 - Scope of
More informationIndia releases Annual Report covering transfer pricing and international tax developments
5 September 2014 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 informationIndia revises Country Chapter comments in UN Practical Manual on Transfer Pricing Issues for Developing Countries
14 November 2016 Global Tax Alert News from Transfer Pricing India revises Country Chapter comments in UN Practical Manual on Transfer Pricing Issues for Developing Countries EY Global Tax Alert Library
More informationIFRS 12. Disclosure of Interests in Other Entities
IFRS 12 Disclosure of Interests in Other Entities Agenda Background and objectives Main changes to disclosure requirements Summarised financial information Other disclosure requirements for subsidiaries,
More informationSaint Lucia complies with its international commitments while maintaining its attractiveness to investors
12 December 2018 Global Tax Alert Saint Lucia complies with its international commitments while maintaining its attractiveness to investors NEW! EY Tax News Update: Global Edition EY s new Tax News Update:
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 informationNew Zealand to implement wide ranging international tax reforms
15 August 2017 Global Tax Alert New Zealand to implement wide ranging international tax reforms EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your
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 informationLet s talk: governance
EY Center for Board Matters Let s talk: governance June 2014 Issue 6 First-year conflict mineral reporting reveals insights and surprises First-year conflict mineral reporting reveals insights and surprises
More informationEY Transaction Advisory Services. Transaction Support. Luxembourg
EY Transaction Advisory Services Transaction Support Luxembourg EY Transaction Advisory Services Transaction Support Luxembourg We find the answers to your questions and focus on your needs Are there
More informationJoint Transition Resource Group for Revenue Recognition discusses more implementation issues
Applying IFRS Joint Transition Resource Group for Revenue Recognition discusses more implementation issues April 2015 Contents 1. Overview... 2 2. Issues that may require further evaluation by the Boards...
More informationEY UK Tax Strategy. Financial year ending 30 June 2017
EY UK Tax Strategy Financial year ending 30 June 2017 EY s values and our commitment to building a better working world drive our tax strategy Scope This tax strategy applies to EY LLP and all its wholly
More informationIPO destination guide. Find the right market strategy to maximize value for your IPO or secondary listing
IPO destination guide Find the right market strategy to maximize value for your IPO or secondary listing You've decided to go public and now you need to map out all the necessary steps. ut to determine
More informationThe global tax disputes environment
The global tax disputes environment How the tax disputes teams of multinational corporations are managing, responding and evolving Global Tax Disputes benchmarking survey 2016 KPMG International kpmg.com/tax
More informationHong Kong s OECD BEPS Associate status requires implementation of BEPS minimum standards
28 June 2016 International Tax and TP Alert Hong Kong s OECD BEPS Associate status requires implementation of BEPS minimum standards Executive summary On 20 June 2016, Hong Kong announced that it will
More informationRisk-based capital and governance in Asia-Pacific: emerging regulations
Risk-based capital and governance in Asia-Pacific: emerging regulations 1 Changing regulations in a changing market Across the Asia-Pacific region, countries are reviewing their approach to regulation
More informationAustralia issues draft tax guidelines regarding transfer pricing documentation, penalties and reconstruction
17 April 2014 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 informationMergers, acquisitions and capital-raising in mining and metals trends, 2014 outlook: changing gear. The CFO perspective at a glance
Mergers, acquisitions and capital-raising in mining and metals 2013 trends, 2014 outlook: changing gear The CFO perspective at a glance The CFO perspective at a glance We want to help you get to the insight
More informationApplying IFRS. TRG addresses more revenue implementation issues. November 2015
Applying IFRS TRG addresses more revenue implementation issues November 2015 Contents Overview 2 1. Accounting for renewals and restrictions in licences of IP 2 2. Update on previous TRG issues 4 3. What
More informationBrexit for insurance. Mapping the road to Brexit
Brexit for insurance Mapping the road to Brexit 3 A step-by-step guide to designing and implementing a strategy to meet the challenges of a post-brexit world With the clock ticking on the UK s exit from
More informationMauritius enacts changes to tax regime for corporations with global business licenses
17 August 2018 Global Tax Alert Mauritius enacts changes to tax regime for corporations with global business licenses NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is
More informationThe new revenue recognition standard - life sciences
Applying IFRS in Life Sciences The new revenue recognition standard - life sciences November 2014 Contents Overview... 2 Key considerations for life sciences entities... 2 Collaboration agreements... 2
More informationIrish Government announces Budget 2016 and publishes update on international tax strategy
16 October 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 Irish
More informationEuropean Parliament votes in favor of public Country-by- Country reporting in first reading
7 July 2017 Global Tax Alert European Parliament votes in favor of public Country-by- Country reporting in first reading EY Global Tax Alert Library Access both online and pdf versions of all EY Global
More informationAsia Pacific Customs and Trade Conference
www.pwccustoms.com Asia Pacific Customs and Trade Conference What the BEPS?!? Frank Debets, Partner, WMS Singapore Howard Osawa, Director, WMS Japan Agenda Introduction to BEPS Potential impact of BEPS
More informationA vision for banking transformation is emerging take note
Global Regulatory Reform A vision for banking transformation is emerging take note Structural business change in European banking Introduction 1 01 02 03 Dealing with structural reform is at the core of
More informationFraud risk management. Oil and gas sector
Fraud risk management Oil and gas sector Fraud risk management oil and gas sector Contents Why should you be concerned about fraud risks? 1 Key risks in the oil and gas sector 2 Five key factors your business
More informationAIF Club. Risk and liquidity management for Private Equity and Real Estate Funds
AIF Club Risk and liquidity management for Private Equity and Real Estate Funds B AIF Club Risk and liquidity management for Private Equity and Real Estate Funds Introduction Risk management is one of
More informationIntangibles in transfer pricing: A look at the new OECD guidance and Japanese regulations
4 April 2016 Japan tax alert Ernst & Young Tax Co. Intangibles in transfer pricing: A look at the new OECD guidance and Japanese regulations EY Global tax alert library Access both online and pdf versions
More information