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25 November 2018

U.S. International Tax This Week for November 21

Ernst & Young's U.S. International Tax This Week newsletter for the week ending November 21 is now available. Prepared by Ernst & Young's International Tax Services group, this weekly update summarizes important news, cases, and other developments in international taxation.

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Spotlight

The United States and Singapore signed a tax information exchange agreement (TIEA) and a new Foreign Account Tax Compliance Act (FATCA) Model I Intergovernmental Agreement (IGA) on 13 November. The TIEA covers all US federal taxes as well as Income Tax, Property Tax, Goods and Services Tax and Stamp Duty in Singapore. The new reciprocal FATCA IGA will supersede the current 2014 non-reciprocal IGA when it enters into force.

There were a number of Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) developments in recent days. On 15 November, the OECD released an update to the 2017 Progress report on Preferential Tax Regimes conducted in connection with Action 5 of the BEPS Project. The updated results cover 53 regimes, bringing the number of regimes reviewed, or under review, to 246. The assessments were undertaken by the Forum on Harmful Tax Practices.

On the same date, the Inclusive Framework on BEPS released a Substantial Activities Requirement for "no or only nominal tax" jurisdictions (the Standard). The document sets out the background and rationale for the resumption of the substantial activities requirement, a requirement first set out in an OECD 1998 report. It also sets out the technical guidance governing the application of that requirement.

Finally, the OECD in mid-November announced that it is now gathering input on the implementation of the BEPS Action 14 minimum standard in relation to the review of the seventh batch of jurisdictions (Brazil, Bulgaria, China, Hong Kong, Indonesia, Papua New Guinea, Russian Federation and Saudi Arabia). The OECD is inviting taxpayers to submit their input related to their experiences in these jurisdictions via electronic questionnaire by 13 December. This exercise is part of the process of the mutual agreement procedure (MAP) peer review and monitoring process that the OECD launched in December 2016 under Action 14 of the BEPS project in relation to more effective dispute resolution mechanisms.

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Upcoming Webcasts

EU mandatory disclosure regime (November 28)
The shifting landscape in relation to MDR brings challenges for taxpayers and intermediaries alike. During this Thought Center Webcast, Ernst & Young professionals will discuss managing their own reporting obligations, coordinating with their intermediaries and keeping abreast of country developments.

BorderCrossings... With EY transfer pricing and tax professionals (November 29)
During this Thought Center Webcast, Ernst & Young professionals will help you stay informed and able to adopt a more proactive stance in developing and defending your transfer pricing policies and practices.

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Recent Tax Alerts

United States

Africa

Canada & Latin America

Europe

Middle East

Oceania

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Additional Resources

Ernst & Young Client Portal, the leading source for news, analysis, and reference materials for corporate tax professionals, has a variety of content of interest to international tax practitioners, including:

— International Tax Online Reference Service. Key information about, and important tax developments from, 56 foreign jurisdictions, including information on tax rates, interest rates and penalties, withholding, and filing dates.

— EY/Passport. EY/Passport is your guide to planning ventures in the global economy, offering a wealth of tax and business knowledge on more than 150 countries.

Because the matters covered herein are complicated, U.S. International Tax This Week should not be regarded as offering a complete explanation and should not be used for making decisions. Any decision concerning matters covered herein should be reviewed with a qualified tax advisor.

Document ID: 2018-2338

 

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