Canada Revenue Agency releases proposed changes to GST/HST Voluntary Disclosure Program
|
|
- Lydia Doyle
- 5 years ago
- Views:
Transcription
1 22June 2017 Global Tax Alert News from Americas Tax Center Canada Revenue Agency releases proposed changes to GST/HST Voluntary Disclosure Program EY Global Tax Alert Library The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the region to help clients address administrative, legislative and regulatory opportunities and challenges in the 33 countries that comprise the Americas region of the global EY organization. Copy into your web browser: Tax/Americas-Tax-Center---borderlessclient-service Executive summary On 9 June 2017, the Canada Revenue Agency (CRA) released proposed changes to the Voluntary Disclosures Program (VDP). The changes follow an extensive review of the program in response to the recommendation to the Government by the House of Commons Standing Committee on Finance in October 2016, as well as recommendations made by the Offshore Compliance Advisory Committee on 5 December Notably, the CRA intends to separate the VDP policy for disclosures involving income tax and source deductions from the VDP policy for Goods and Services Tax (GST)/Harmonized Sales Tax (HST), excise tax, excise duties, softwood lumber products export charges and air travellers security charges. Major changes to the CRA s VDP policy for GST/HST include the following: Applications will be processed under three different tracks, and less generous relief, or, in some cases, no relief will be available in major cases of noncompliance. VDP relief will not be available if a registrant attempts to increase the amount of input tax credits, rebates or other credit adjustments without any corresponding increase in tax liability. Registrants will be required to pay the estimated tax owing at the time they apply for VDP relief.
2 2 Global Tax Alert Americas Tax Center The CRA is seeking input on the proposed changes during a 60-day online consultation period ending 8 August The final changes to the VDP policy will be announced in the fall and will apply as of 1 January Detailed discussion Background The VDP applies to disclosures relating to income tax, sources deductions, GST/HST, excise tax, excise duties, softwood lumber products export charges and air travellers security charges. Subject to certain eligibility requirements, registrants may correct inaccurate or incomplete information they have previously provided to the CRA or disclose information they have not previously provided. Under the current policy, a registrant that makes a valid disclosure is liable to the taxes owing (plus interest) but is not subject to penalties or prosecution. In some cases, the interest may be reduced, waived or cancelled as well. For GST/HST purposes, section 281.1, section 284, and subsection 284.1(3) of the Excise Tax Act provide the legislative discretionary authority to the Minister of National Revenue to waive or cancel penalties and interest. The proposed changes released by the CRA on 9 June 2017 are outlined in a draft new GST/HST Memorandum 16.5, Voluntary Disclosures Program (the draft GST/HST memorandum). The draft GST/HST memorandum addresses GST/HST, excise tax, excise duty, softwood lumber products export charges, and air travellers security charges VDP matters. The CRA has also released a draft version of Information Circular IC00-1R6, Voluntary Disclosures Program, which provides information on the CRA s VDP policy for disclosures related to income tax and source deductions. Both documents and the changes to the VDP they contain will be finalized this coming fall and will be applicable after 31 December This Alert focuses on the changes to the VDP policy for GST/HST, excise tax, excise duties, softwood lumber products export charges, and air travellers security charges. Refer to our separate Global Tax Alert for details on the changes to the VDP policy changes for disclosures involving income tax and source deductions. Introduction of three tracks The CRA proposes to process GST/HST VDP applications under three tracks: Track 1 GST/HST wash transactions: Full interest and penalty relief may be provided for GST/HST wash transactions. Under GST/HST Memorandum , Reduction of Penalty and Interest in Wash Transaction Situations, a wash transaction refers to a situation where a supplier has failed to charge and collect GST/HST from a registrant that is entitled to claim a full input tax credit (ITC). A wash transaction may also occur within a closely related or associated group of persons where ITCs are claimed by the wrong entity. Track 2 General Program: Track 2 provides relief for applications disclosing non-compliance or errors, including situations involving: Wash transactions that are ineligible for a reduction of penalty and interest in accordance with policies set out in GST/HST Memorandum Reasonable errors Failure to file information returns No gross negligence or deliberate tax avoidance Over-claimed rebates As an example of Track 2 application, the CRA cites a hypothetical scenario where a registrant claimed excessive ITCs due to an accounting error. Track 3 Limited Program: Limited relief may be provided for applications disclosing major non-compliance. The CRA will consider an application to involve major non-compliance if one or more of the following are present: GST/HST charged or collected but not remitted Active efforts to avoid detection (e.g., participation in the underground economy) Large dollar amounts Multiple years of non-compliance A sophisticated registrant Deliberate or wilful default or carelessness amounting to gross negligence Any other circumstance in which a high degree of registrant culpability contributed to the failure to comply
3 Global Tax Alert Americas Tax Center 3 Conditions of a valid application Under the proposed changes, in order for a VDP application to qualify for relief, the application must meet the following requirements: Be voluntary Be complete Involve the application or potential application of a penalty or interest Include information that is at least one reporting period past due Include payment of the estimated tax owing The CRA may consider alternative payment arrangements (supported by adequate security) in extraordinary circumstances. However, to support the inability to pay, the registrant will be required to make full disclosure and provide evidence of income, expenses, assets and liabilities. The draft GST/HST memorandum stipulates that a registrant s VDP application for a particular issue must be made for taxation years or fiscal or reporting periods where there was previously inaccurate, incomplete or unreported information regarding their tax affairs as follows: For Track 1, the four years before the application s filing date For Track 2, the six years before the application s filing date For Track 3, all relevant years Under current policy, a VDP application must involve the application or potential application of a penalty. The proposed changes specifically provide that the CRA will consider disclosures involving the application or potential application of interest as well. Interest relief Where the CRA accepts a VDP application, interest relief in respect of assessments resulting from the application is available as follows: For Track 1, 100% interest relief For Track 2, relief for 50% of the applicable interest For Track 3, no interest relief The Minister may grant interest relief for interest that accrued during the previous 10 calendar years before the calendar year in which the registrant files the VDP application. Penalty relief Where the CRA accepts a Track 1 or Track 2 VDP application, full penalty relief will be provided, subject to the 10-year limitation period (consistent with current VDP policy). Penalty relief is generally not available for a VDP application Track 3. However, the CRA will not assess a gross negligence penalty even if the facts establish that the registrant is liable for such a penalty. Circumstances where no VDP relief will be granted In addition to current VDP application restrictions (for example, the CRA does not accept VDP applications relating to statutory elections), the draft GST/HST memorandum indicates that VDP applications will not be accepted where a registrant is attempting to increase the amount of input tax credits, rebates, or other credit adjustments without any corresponding increase in tax liability for the relevant period. Application form Registrants will be required to use Form RC199, Voluntary Disclosures Program (VDP) Taxpayer Agreement, for all applications made under the new policy. No-name disclosures (see below) may also be made using Form RC199. If a registrant s authorized representative submits the application, the form must be signed by both the registrant and the authorized representative. Currently, registrants who are unsure if they want to submit a VDP application may engage in informal and non-binding preliminary discussions with the CRA on a no-name basis. These discussions occur before the registrant s identity is revealed. On the basis of the preliminary information provided by the registrant, the VDP officer may confirm whether there is anything that would immediately disqualify the registrant from VDP consideration. If all the required information for a complete disclosure (other than the registrant s identity) has been submitted and the registrant so requests, the officer may review the information and advise the registrant on the tax implications of the disclosure, without prejudice. While no-name disclosures will remain available under the new administrative policy, neither the draft GST/HST memorandum nor Information Circular IC00-1R6 provide much detail beyond confirming that preliminary discussions will be informal, non-binding and general in nature. As a result, it is not clear whether the CRA will administer noname disclosures in full accordance with current policy.
4 4 Global Tax Alert Americas Tax Center Second VDP application In general, a registrant is entitled to obtain the benefits of the VDP only once. The CRA will not normally consider a second application unless the circumstances surrounding the second application meet the following: Are beyond the registrant s control Relate to a different matter than the first application Objection rights If a registrant s application is accepted under Track 3, the registrant will be required to waive their right to object in relation to the specific matter that was disclosed in the VDP application, and any assessment (or reassessment) of taxes that specifically relate to that disclosure. This waiver will not prevent a registrant from filing an objection in circumstances involving calculation errors, characterization issues (e.g., taxable vs. exempt supplies), or to an issue unrelated to the matter disclosed in the VDP application. Endnote 1. See IC 00-1R5, Voluntary Disclosures Program,
5 Global Tax Alert Americas Tax Center 5 For additional information with respect to this Alert, please contact the following: Ernst & Young LLP (Canada), East Jean-Hugues Chabot jean-hugues.chabot@ca.ey.com Daniel P. Legault daniel.p.legault@ca.ey.com Manon Jubinville manon.jubinville@ca.ey.com Ernst & Young LLP (Canada), Central Dalton Albrecht dalton.albrecht@ca.ey.com Jan Pedder jan.s.pedder@ca.ey.com Sania Ilahi sania.ilahi@ca.ey.com Ernst & Young LLP (Canada), West Katherine Xilinas katherine.xilinas@ca.ey.com David D. Robertson david.d.robertson@ca.ey.com
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 2017 EYGM Limited. All Rights Reserved. EYG no Gbl NY ED None 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
Tax Alert Canada. Changes to GST/HST VDP revised
2017 Issue No. 54 19 December 2017 Tax Alert Canada Changes to GST/HST VDP revised EY Tax Alerts cover significant tax news, developments and changes in legislation that affect Canadian businesses. They
More informationCanada Revenue Agency releases proposed changes to income tax Voluntary Disclosure Program
22 June 2017 Global Tax Alert News from Americas Tax Center Canada Revenue Agency releases proposed changes to income tax Voluntary Disclosure Program EY Global Tax Alert Library The EY Americas Tax Center
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: Revenu Québec implements new mandatory certificate for personnel placement agencies and subcontractors
23 June 2016 Global Tax Alert News from Americas Tax Center Canada: Revenu Québec implements new mandatory certificate for personnel placement agencies and subcontractors EY Global Tax Alert Library The
More informationThe following is a summary of the measures included in the 8 September 2017 GST/HST legislative proposals.
2017 Issue No. 39 13 September 2017 Tax Alert Canada Finance releases GST/HST draft legislation EY Tax Alerts cover significant tax news, developments and changes in legislation that affect Canadian businesses.
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 informationCanada Revenue Agency revises income tax Voluntary Disclosures Program
20 December 2017 Global Tax Alert News from Americas Tax Center Canada Revenue Agency revises income tax Voluntary Disclosures Program EY Global Tax Alert Library The EY Americas Tax Center brings together
More informationIndirect Tax Alert. Canada releases draft legislation for sales tax technical amendments
21 April 2014 Canada releases draft legislation for sales tax technical amendments Executive summary On 8 April 2014, Canada s Department of Finance released for public comment draft legislative proposals
More informationVOLUNTARY DISCLOSURES - PART I
VOLUNTARY DISCLOSURES - PART I This issue of the Legal Business Report provides current information to the clients of Alpert Law Firm on the rules relating to the tax treatment of Voluntary Disclosures.
More informationVoluntary Disclosures Program (VDP) Application
Voluntary Disclosures Program (VDP) Application Canada Revenue Agency Stamp DO NOT USE THIS AREA Use this form to make an application to correct inaccurate or incomplete information, or to disclose information
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 informationTax Alert Canada. Changes to income tax VDP revised. Overview
2017 Issue No. 53 19 December 2017 Tax Alert Canada Changes to income tax VDP revised EY Tax Alerts cover significant tax news, developments and changes in legislation that affect Canadian businesses.
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 informationTax Alert Canada. Changes to the large business simplified method and clarification for its application to expenses incurred before 1 January 2014
2013 Issue No. 37 31 July 2013 Tax Alert Canada Changes to the large business simplified method and clarification for its application to expenses incurred before 1 January 2014 EY Tax Alerts cover significant
More informationPuerto Rico extends automatic extension period for filing a 2017 tax return from three months to six months
17 April 2018 Global Tax Alert News from Americas Tax Center Puerto Rico extends automatic extension period for filing a 2017 tax return from three months to six months EY Global Tax Alert Library The
More informationCanada: Prince Edward Island issues budget
10 April 2018 Global Tax Alert News from Americas Tax Center Canada: Prince Edward Island issues budget 2018-19 EY Global Tax Alert Library The EY Americas Tax Center brings together the experience and
More informationTax Alert Canada. US sales and use tax ramifications for Canadian e-commerce vendors following US Supreme Court judgment.
2018 Issue No. 25 9 July 2018 Tax Alert Canada US sales and use tax ramifications for Canadian e-commerce vendors following US Supreme Court judgment EY Tax Alerts cover significant tax news, developments
More informationGST/HST Memoranda Series
GST/HST Memoranda Series 16.3 January 2009 Cancellation or Waiver of Penalties and/or Interest Note: This memorandum of Chapter 16 supersedes GST Memorandum 500-3-2-1, Cancellation or Waiver of Penalties
More informationCanada: provisional implementation of trade agreement with EU is delayed to Fall 2017 due to dairy, pharmaceuticals and ISDS disputes
26 July 2017 Indirect Tax Alert News from Americas Tax Center Canada: provisional implementation of trade agreement with EU is delayed to Fall 2017 due to dairy, pharmaceuticals and ISDS disputes EY Global
More informationGST/HST Memoranda Series
GST/HST Memoranda Series 16.3.1 April 2010 Reduction of Penalty and Interest in Wash Transaction Situations Note: This memorandum supersedes GST/HST Memorandum 16.3.1, Reduction of Penalty and Interest
More informationTable of contents INCOME TAX INFORMATION CIRCULAR. Taxpayer Relief Provisions
INCOME TAX INFORMATION CIRCULAR NO. IC07-1R1 DATE: August 18, 2017 SUBJECT: Taxpayer Relief Provisions This information circular is only available electronically. References to the act and the regulations
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 informationGreece enacts changes in transfer pricing penalties and issues guidance on transfer pricing documentation and audit issues
27 October 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 informationCanada: Yukon issues budget
28 April 2017 Global Tax Alert News from Americas Tax Center Canada: Yukon issues budget 2017-18 EY Global Tax Alert Library The EY Americas Tax Center brings together the experience and perspectives of
More informationAustralian Tax Office releases guide for offshore hubs involving procurement, marketing, sales and distribution functions
24 January 2017 Global Tax Alert News from Transfer Pricing Australian Tax Office releases guide for offshore hubs involving procurement, marketing, sales and distribution functions EY Global Tax Alert
More informationCanada: Saskatchewan issues budget
11 April 2018 Global Tax Alert News from Americas Tax Center Canada: Saskatchewan issues budget 2018-19 EY Global Tax Alert Library The EY Americas Tax Center brings together the experience and perspectives
More informationOffshore Compliance Advisory Committee
2016 Offshore Compliance Advisory Committee REPORT ON THE VOLUNTARY DISCLOSURES PROGRAM P a g e 1 Offshore Compliance Advisory Committee Report on the Voluntary Disclosures Program Introduction The Offshore
More informationCanada: British Columbia introduces employer health tax legislation
25 October 2018 Indirect Tax Alert News from Americas Tax Center Canada: British Columbia introduces employer health tax legislation NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global
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 informationCanada: Federal Court of Appeal reaffirms existence of common interest privilege outside a litigation context
20 March 2018 Global Tax Alert News from Americas Tax Center Canada: Federal Court of Appeal reaffirms existence of common interest privilege outside a litigation context EY Global Tax Alert Library The
More informationNorway to impose new tax liability rules and requirements for applying reduced withholding tax rate on dividend payments to foreign shareholders
28 March 2017 Global Tax Alert Norway to impose new tax liability rules and requirements for applying reduced withholding tax rate on dividend payments to foreign shareholders EY Global Tax Alert Library
More informationTax Alert Canada. Duty relief, duty drawback, and remission available for Canadian surtaxes on certain US originating goods.
2018 Issue No. 29 19 July 2018 Tax Alert Canada Duty relief, duty drawback, and remission available for Canadian surtaxes on certain US originating goods EY Tax Alerts cover significant tax news, developments
More informationCanada: Nunavut issues budget
30 May 2018 Global Tax Alert News from Americas Tax Center Canada: Nunavut issues budget 2018-19 NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized
More informationCanadian Federal Court of Appeal denies Canada Revenue Agency request for tax working papers
4 April 2017 Global Tax Alert News from Americas Tax Center Canadian Federal Court of Appeal denies Canada Revenue Agency request for tax working papers EY Global Tax Alert Library The EY Americas Tax
More informationAustralia s proposed Diverted Profits Tax to affect many multinational businesses
2 December 2016 Global Tax Alert Australia s proposed Diverted Profits Tax to affect many multinational businesses EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts.
More informationIndia s CBEC extends LUT facility in respect of all zero-rated supplies
12 October 2017 Indirect Tax Alert India s CBEC extends LUT facility in respect of all zero-rated supplies EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy
More informationCanadian Revenue Minister announces measures to combat aggressive tax avoidance and offshore tax evasion
12 April 2016 Global Tax Alert News from Americas Tax Center Canadian Revenue Minister announces measures to combat aggressive tax avoidance and offshore tax evasion EY Global Tax Alert Library The EY
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 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 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 informationSouth Africa proposes amendments to hybrid debt and hybrid equity instrument legislation
12 July 2016 Global Tax Alert South Africa proposes amendments to hybrid debt and hybrid equity instrument legislation EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax
More informationCanada: British Columbia issues budget
23 February 2017 Global Tax Alert News from Americas Tax Center Canada: British Columbia issues budget 2017-18 EY Global Tax Alert Library The EY Americas Tax Center brings together the experience and
More informationCanada: Ontario issues budget
29 March 2018 Global Tax Alert News from Americas Tax Center Canada: Ontario issues budget 2018-19 EY Global Tax Alert Library The EY Americas Tax Center brings together the experience and perspectives
More informationUK Government opens consultations on Making Tax Digital
16 August 2016 Global Tax Alert UK Government opens consultations on Making Tax Digital EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser:
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 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 informationIsrael reduces limitations on tax free reorganizations
24 August 2017 Global Tax Alert Israel reduces limitations on tax free reorganizations EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser:
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 informationCanada: Québec issues budget
28 March 2018 Global Tax Alert News from Americas Tax Center Canada: Québec issues budget 2018-19 EY Global Tax Alert Library The EY Americas Tax Center brings together the experience and perspectives
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 informationRussian Government issues bill for implementation of Automatic Exchange of Financial Account Information
19 September 2016 Global Tax Alert Russian Government issues bill for implementation of Automatic Exchange of Financial Account Information EY Global Tax Alert Library Access both online and pdf versions
More informationSouth African Tax Authority clarifies corporate tax classification of risk policies and once-off election for long-term insurers
17 February 2017 Global Tax Alert South African Tax Authority clarifies corporate tax classification of risk policies and once-off election for long-term insurers EY Global Tax Alert Library Access both
More informationDanish Tax Board rules that Scandinavian sales manager s work from home creates PE for German company
19 April 2017 Global Tax Alert Danish Tax Board rules that Scandinavian sales manager s work from home creates PE for German company EY Global Tax Alert Library Access both online and pdf versions of all
More informationSingapore releases Budget 2018
26 February 2018 Global Tax Alert Singapore releases Budget 2018 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 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 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 informationCanada: British Columbia issues budget update
13 September 2017 Global Tax Alert News from Americas Tax Center Canada: British Columbia issues budget update 2017 18 EY Global Tax Alert Library The EY Americas Tax Center brings together the experience
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 informationGulf Cooperation Council VAT may impact international law firms
22 August 2017 Indirect Tax Alert Gulf Cooperation Council VAT may impact international law firms EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into
More informationCanada releases draft income tax proposals for public comment
12 September 2017 Global Tax Alert News from Americas Tax Center Canada releases draft income tax proposals for public comment EY Global Tax Alert Library The EY Americas Tax Center brings together the
More informationTax Alert Canada. Invoices of accommodation: Important Federal Court of Appeal decision in Salaison Lévesque Inc. Background
2015 Issue No. 3 21 January 2015 Tax Alert Canada EY Tax Alerts cover significant tax news, developments and changes in legislation that affect Canadian businesses. They act as technical summaries to keep
More informationMalaysia releases 2019 Budget
4 December 2018 Global Tax Alert Malaysia releases 2019 Budget NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email subscription service that allows
More informationCanadian personal tax increases on non-eligible dividends scheduled for 2018 and 2019
27 November Global Tax Alert News from Americas Tax Center Canadian personal tax increases on non-eligible dividends scheduled for and EY Global Tax Alert Library The EY Americas Tax Center brings together
More informationUK publishes Autumn Finance Bill 2017
11 September 2017 Global Tax Alert UK publishes Autumn Finance Bill 2017 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 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 informationNew EU VAT rules simplify VAT for e-commerce
29 March 2018 Indirect Tax Alert New EU VAT rules simplify VAT for e-commerce 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 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 informationCanada s Federal budget impacts Canadian private company sale transactions
4 April 2016 Global Tax Alert News from Americas Tax Center Canada s Federal budget 2016-17 impacts Canadian private company sale transactions EY Global Tax Alert Library The EY Americas Tax Center brings
More informationUS IRS issues examination guidelines on Form 1120-F filing deadline waivers
2 March 2018 Global Tax Alert US IRS issues examination guidelines on Form 1120-F filing deadline waivers EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy
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 s GST Council reduces rates for certain supplies and approves rules on e-way bill
16 August 2017 Indirect Tax Alert India s GST Council reduces rates for certain supplies and approves rules on e-way bill EY Global Tax Alert Library Access both online and pdf versions of all EY Global
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 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 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 informationUS: Forthcoming proposed regulations will offer some clarity on Section 163(j) business interest expense limitation
9 April 2018 Global Tax Alert US: Forthcoming proposed regulations will offer some clarity on Section 163(j) business interest expense limitation EY Global Tax Alert Library Access both online and pdf
More informationIndia s Authority of Advance Rulings grants capital gains tax exemption under India Mauritius Treaty
22 September 2016 Global Tax Alert India s Authority of Advance Rulings grants capital gains tax exemption under India Mauritius Treaty EY Global Tax Alert Library Access both online and pdf versions of
More informationBrazil amends regulations related to taxation of capital gains earned by nonresidents and cross-border payments related to rental or lease of aircraft
20 October 2016 Global Tax Alert News from Americas Tax Center Brazil amends regulations related to taxation of capital gains earned by nonresidents and cross-border payments related to rental or lease
More informationWe would be pleased to meet with you should you consider useful to discuss any aspect of this letter in further detail.
January 25, 2012 Ms Josée Morin Assistant Deputy Minister, droit fiscal et à la fiscalité Ministère des Finances du Québec 12, rue Saint-Louis, étage B QUÉBEC (QC) G1R 5L3 Re: Harmonization of the TVQ
More informationFrench Government submits draft bill on digital services tax to Council of Ministers
8 March 2019 Indirect Tax Alert French Government submits draft bill on digital services tax to Council of Ministers NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is
More informationCanada: British Columbia issues budget
21 February 2018 Global Tax Alert News from Americas Tax Center Canada: British Columbia issues budget 2018-19 EY Global Tax Alert Library The EY Americas Tax Center brings together the experience and
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 informationDutch Lower Court requests Dutch Supreme Court to reconsider its case law on withholding tax reclaim requests filed by foreign investment funds
6 September 2016 Global Tax Alert Dutch Lower Court requests Dutch Supreme Court to reconsider its case law on withholding tax reclaim requests filed by foreign investment funds EY Global Tax Alert Library
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 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 informationComplaints and Disputes
Complaints and Disputes includes information about CRA Service Complaints Program RC4540(E) Rev. 16 Is this guide for you? T his guide is for you if you are not satisfied with the service, the assessment,
More informationOECD releases Luxembourg peer review report on implementation of Action 14 Minimum Standards
22 December 2017 Global Tax Alert OECD releases Luxembourg peer review report on implementation of Action 14 Minimum Standards EY Global Tax Alert Library Access both online and pdf versions of all EY
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 informationKuwait investment authority clarifies means and conditions for tax exemption of investments
29 January 2016 Global Tax Alert Kuwait investment authority clarifies means and conditions for tax exemption of investments EY Global Tax Alert Library Access both online and pdf versions of all EY Global
More informationUS IRS concludes gain recognition agreements and related filings not affected by short tax years
30 November 2017 Global Tax Alert US IRS concludes gain recognition agreements and related filings not affected by short tax years EY Global Tax Alert Library Access both online and pdf versions of all
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 informationOECD releases Germany peer review report on implementation of Action 14 Minimum Standards
21 December 2017 Global Tax Alert OECD releases Germany peer review report on implementation of Action 14 Minimum Standards EY Global Tax Alert Library Access both online and pdf versions of all EY Global
More informationUK CFC rules: European Commission publishes opening decision on State aid
20 November 2017 Global Tax Alert UK CFC rules: European Commission publishes opening decision on State aid EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts.
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 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 informationEuropean Parliament calls for legislative framework governing creation, use and taxation of robots and artificial intelligence
9 February 2017 Global Tax Alert European Parliament calls for legislative framework governing creation, use and taxation of robots and artificial intelligence EY Global Tax Alert Library Access both online
More informationKenya Revenue Authority issues guidelines on tax amnesty on foreign income
15 March 2017 Global Tax Alert Kenya Revenue Authority issues guidelines on tax amnesty on foreign income EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy
More informationSwiss canton of Zug releases plan for local implementation of Corporate Tax Reform III
4 October 2016 Global Tax Alert Swiss canton of Zug releases plan for local implementation of Corporate Tax Reform III EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax
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 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 information