EY - Americas Tax Center Weekly Roundup

Americas Tax Center Weekly Roundup

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The Americas Tax Center weekly roundup summarizes the most recent and relevant tax news from the Americas and around the world. Note: English language editions are usually posted by late Friday; Spanish editions are posted on Monday.

October 2014

October 17English | Español
Chile tax reform is enacted * Brazil issues new rules for foreign investments in securities and financial markets and Depositary Receipts * Colombia issues new list of tax havens * El Salvador publishes revised list of tax havens for 2015 * Panama's General Revenue Department replaces National Revenue Authority * Ecuador enacts Monetary Act

October 10English | Español
Colombian Government proposes tax reform * Colombia's Constitutional Court rules thin capitalization rule constitutional * Brazil-France Social Security Totalization Agreement enters into force * 2014 Worldwide Transfer Pricing Reference Guide released

October 3English | Español
Chile enacts tax reform * Brazil clarifies requirements related to new corporate tax regime * Mexico issues fifth amendment to Miscellaneous Tax Resolution * Peru-Mexico tax treaty effective 1 January 2015 * Costa Rica requires large taxpayers to update relevant tax information through new web-based platform

September 2014

September 26English | Español
OECD BEPS Action Plan reports released – detailed Tax Alerts now available, webcasts scheduled * El Salvador approves tax amnesty program

September 19English | Español
OECD releases highly anticipated 2014 output of BEPS Action Plan * Chilean Congress approves tax reform * Mexico’s proposed 2015 Federal Revenue Act would extend 4.9% interest withholding tax rate to 31 December 2015 * Brazilian ruling issued on withholding tax treatment applicable to vessel charter payments

September 12English | Español
OECD to release multiple BEPS reports and recommendations * Chile passes tax reform * Uruguay offers tax exemptions for activities performed by MNCs’ shared service centers * Buenos Aires imposes two turnover tax withholding systems on nonresidents * Canada’s Department of Finance releases draft financial services tax measures * Now available: EY’s 2014 Tax risk and controversy survey report, Managing operational tax risk

September 5English | Español
Canada releases draft international tax measures, budget measures * Brazil enacts law eliminating proof of fiscal regularity to register corporate acts * Panamanian Supreme Court rules requirement to pay stamp taxes on documents filed with public authorities unconstitutional * Bolivia postpones implementation of new e-billing system to November 2014 * New Dominican Republic–Spain tax treaty in force

August 2014

August 22English | Español
Chile’s MOF presents amendments to tax reform * US updates procedures for withholding foreign partnerships and withholding foreign trusts * Brazil clarifies certain amounts paid to foreign legal entities are payments for the provision of services

August 15English | Español
Mexico enacts new fiscal system for oil and gas industry - OECD issues Standard for Automatic Exchange of Information in Tax Matters - OECD releases report on effect of BEPS in low income countries - Peruvian President proposes tax changes to promote economic growth - OECD seeks input on collecting and analyzing data on BEPS

August 8English | Español
El Salvador amends Tax Code and Income Tax Law, introduces Financial Transactions Tax Law*Costa Rica requires large taxpayers to keep electronic records for purchases and sales *Uruguayan tax authorities rule on corporate income tax exemption *Latest update on OECD’s BEPS project available *EY issues latest Rapid-Growth Markets Forecast

August 1English | Español
Bolivian President signs transfer pricing legislation – Uruguay issues VAT reduction regulation and offers benefits for shares in international financial institutions; releases transfer pricing ruling – UK, Canada sign amending tax protocol

July 2014

July 25English | Español
OECD publishes Standard for Automatic Exchange of Financial Information in Tax Matters, adopts updates to Model Treaty * Peruvian Congress approves tax changes to promote investment * EY’s 2014 Worldwide Family Business Tax Guide now available

July 18English | Español
Mexico issues rules for electronically filing accounting records * Bolivian Deputies Chamber approves transfer pricing bill * Canadian Revenue revises Form T1135 with permanent relief for 2014, Peru-Portugal tax treaty enters into force later years * Peru-Portugal tax treaty enters into force

July 11English | Español
Mexico publishes new maquiladora rules to qualify for PE exemption * Peruvian Executive proposes tax changes to promote investment * Costa Rica issues private letter ruling on tax applicable to indirect transfers of real estate * The latest on BEPS (8 July 2014) released * EY’s Indirect Tax Briefing – latest issue now available

June 2014

June 27English | Español
Mexico issues proposed rules clarifying nonresidents’ capital gains tax * Brazil issues guidance on cross-border tax treatment of technical services * Tax Court of Canada rules in important transfer pricing case * Mexico proposes rule on deduction by financial institutions of remaining balance of allowance for loan losses * Guatemala approves tax amnesty program * Brazil promotes changes in its black and gray listed jurisdictions, reassessing Switzerland and Hungary

June 20English | Español
Costa Rica proposes repeal of tax benefits for investment funds * Uruguay approves new requirements for local buyers and sellers of goods and services * Canadian Mutual Agreement Procedure report reflects improved timelines * New EY report: Banking in emerging markets: Investing for success

June 13English | Español
New Peruvian rules for communicating issuance, transfer and cancelation of Peruvian shares * Brazil amends minimum average maturity for IOF-FX exemption * Curaçao secures status as financial center through new Dutch tax arrangement * Latest on OECD BEPS

June 6English | Español
El Salvador proposes tax reform * Canada revises guidance on requests for transfer pricing documentation * OECD and country officials discuss BEPS project * EU VAT refunds for non-EU businesses require action by 30 June 2014 *

May 2014

May 30English | Español
OECD hosts third webcast update on BEPS project * US IRS releases Competent Authority statistics * The latest on OECD BEPS as of 27 May 2014 * Canadian territory Nunavut budget 2014-15 tabled

May 22English | Español
OECD holds public consultation on TP documentation, CbC reporting * OECD public consultation reviews BEPS action on hybrid mismatch arrangements * Ecuadorian FFIs need customer’s approval before releasing information to US IRS * Canadian Tax Intelligence discusses directors’ liability

May 16English | Español
Brazil enacts major tax reform * More countries supporting OECD’s Common Reporting Standard * Panama treated as having IGA under FATCA * EY’s The latest on BEPS as of 12 May 2014 available * EY releases first report on 2014 tax risk and controversy survey * Private equity-backed IPOs outperform all other exit routes in Latin America

May 9English | Español
US eases enforcement for FATCA compliance until 2016 for certain taxpayers * Mexico's President submits secondary legislation related to energy reform * Brazilian court rules CFC regime incompatible with certain tax treaties * Latest news on OECD BEPS project

May 2English | Español
Canadian Federal Court of Appeal interprets 95(6)(b) as status manipulation rule * Bahamas introduces VAT * Specific tax on incoming international telephone calls ending in El Salvador unconstitutional * New US Tax Controversy and Risk Management Review

April 2014

April 25English | Español
Numerous countries endorse new OECD guidelines for application of VAT to international trade -- Costa Rican taxpayers must correctly register their tax domicile by 5 May 2014 -- EY 2014 Worldwide Corporate Tax Guide available

April 18English | Español
Chile proposes tax reform -- Mexican Supreme Court issues decision on deductibility of pro-rata expenses -- Mexican tax reform imposes upcoming action items and deadlines for IMMEX, Maquiladora companies-- OECD issues new R&D incentive report

April 11English | Español
Tax Alerts available on OECD hybrid mismatch arrangements, digital economy * Canadian Nova Scotia, Prince Edward Island 2014-15 provincial budgets tabled * EY’s 2014 Worldwide VAT, GST and Sales Tax Guide now available * EY’s FATCA website updated with latest developments and service offerings

April 4English | Español
US FATCA relief announced * Numerous countries commit to early adoption of OECD's Common Reporting Standard * Dominican Republic modifies transfer pricing regulations * OECD tentatively announces simplifications to CbC reporting * Argentina and Switzerland sign new tax treaty

March 2014

March 28English | Español
OECD issues BEPS digital economy tax discussion draft * Canadian nonresident trust rules require notice of relieving elections by 31 March or 25 June 2014 * Details available on Venezuela amended Master Law for Fair Prices * Peru's new tax treaties with Switzerland, Korea enter into force

March 21English | Español
OECD releases discussion drafts on treaty abuse, hybrid mismatch arrangements * Chile issues instructions on modifications included in Law 20.630 on international taxation * Brazil issues Normative Instruction dealing with withholding tax on transactions between Brazilian residents and nonresidents * Spanish High Court rules Brazilian juros qualify for participation exemption

March 14English | Español
Colombia issues new procedure for registering tech import contracts with DIAN * Peru ratifies tax treaty with Portugal * Puerto Rico approves tax incentives to promote aircraft maintenance / repair * US tax reform proposal would impact non-US investors in the country * EY Mining & Metals March 2014 Resource nationalism update now available

March 7English | Español
US President releases FY 2015 budget, tax proposals * Colombia modifies transfer pricing regulations * Peru ratifies tax treaties with Switzerland, Korea * El Salvador introduces changes in transfer pricing info return * Canada announces Form T1135 transitional relief for 2013