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.

March 2015

March 27English | Español
Costa Rica proposes reform of Income Tax Law * Guatemala, Mexico sign tax treaty * US Finance Committee international hearing discusses patent boxes * Québec Taxation Review Committee publishes final report with tax reform recommendations * EY ‘Plug in’ report examines Mexican energy reform, other tax developments for Power & Utilities * EY global report: ‘Megatrends 2015: making sense of a world in motion’

March 20English | Español
Panama amends Panama-Pacific Agency Law, exempting certain activities from tax * Saskatchewan budget 2015–16 tabled * Latest update on OECD’s BEPS project available * EY Webcast: New VAT/GST regimes: Driving business transformation (25 March)

March 13English | Español
Honduran tax authorities create new International/TP department and announce TP compliance updates * Canada announces new funding to support mining and oil & gas exploration * EY’s ‘Indirect tax in 2015’ identifies global tax policy trends * ‘Insurance opportunities and tax considerations in Latin America’ – EY report released

March 6English | Español
Puerto Rico proposes tax changes for individuals, conduit entities and corporations * Ecuadoran tax reform affects transactions with related parties * Canada expands on guidance on audits of intra-group services * Tax Court of Canada rules cross-currency swap constitutes hedge * Ecuador removes safeguards to exchange transactions with Colombia and Peru * Panama requires respose to info requests within ‘reasonable time’ * Cayman Islands sets up Automatic Exchange of Information Portal for FATCA submissions

February 2015

February 20English | Español
VAT bill introduced in Puerto Rico * US FY 2016 Budget international tax proposals have implications for US inbound investors * Mexico issues regulations for adjusting value of hydrocarbons * Costa Rica eliminates LIFO as a valid inventory valuation method for tax purposes * OECD hosts sixth webcast update on BEPS * EY's 2015 Global Corporate Development Study issued

February 13English | Español
OECD releases documents on BEPS Actions 5, 13 and 15 * Panama changes deadline for taxpayers to request non-application of alternative minimum income tax * Costa Rica’s web-based platform “AMPO” now live * Canada's new filing obligations in force for GST/HST election for closely related persons * Ecuadorian IRS issues new list of tax haven jurisdictions

February 6English | Español
US President’s FY 2016 Budget includes new details on tax reform * Costa Rica's annual tax on legal entities unconstitutional * Mexican Supreme Court: no deduction for expenses paid by Mexican company to foreign related party with Mexican PE * Mexican Supreme Court rules 10% depreciation rate applies to oil rigs * New funding to support mining in British Columbia, Canada

January 2015

January 30English | Español
OECD holds public consultations on BEPS Actions 6, 7 and 14 * Canada changes customs policy on transfer pricing downward adjustments; refund opportunity * Costa Rican Tax Authorities publish draft decree to create shareholders' registry * Honduras approves tax amnesty * Uruguay, Singapore sign income tax treaty

January 23English | Español
Ecuadorian Government issues regulation to implement new tax reforms * Venezuela amends additional laws through Enabling Act, including Income Tax Law * Costa Rican court lifts suspension of new withholding on credit and debit card payments, effective 15 January 2015 * Canada’s Federal Court of Appeal issues important decision in Salaison Lévesque Inc * Argentina-Luxembourg social security agreement in force * Uruguay approves Tax Information Exchange Agreement with Brazil

January 16English | Español
Nicaragua amends its tax law * Peru enacts new tax changes * Venezuela amends additional laws through Enabling Act * EY’s 2014 Global Transfer Pricing Tax Authority Survey now available

January 9English | Español
Colombia and Ecuador enact tax reform * Mexico publishes oil and gas tax regulations * Argentine Supreme Court rules branches of foreign companies not subject to personal assets tax * Peru expands tax treaty network

December 2014

December 19English | Español
OECD releases additional BEPS discussion drafts * Peru passes corporate income tax changes * Ecuador enacts advance pricing consultations * Argentina approves tax treaty with Switzerland * Honduras approves municipal tax amnesty program * Guatemala introduces tax on telephone lines and amends tax laws

December 12English | Español
Ecuador proposes tax reform * Brazil reduces threshold for determining tax havens and privileged tax regimes * Venezuela amends laws through Enabling Act * Quebec Finance Minister’s economic update contains tax measures * Latest update on OECD’s BEPS project

December 5English | Español
Peru enacts tax changes to promote economic growth * Mexico's IMMEX companies to be required to maintain accounting systems for VAT / excise tax certification * Mexican Supreme Court grants temporary relief from accounting records filing requirement * Uruguay promotes installation of POS terminals and related accessories * Costa Rica revises income tax brackets for 2015

November 2014

November 21English | Español
G-20 Brisbane Communiqué highlights new developments on global tax issues * Argentine tax authorities aggressively examining foreign trade transactions * Panama approves tax amnesty program, amends Fiscal Code * Uruguay changes migration regulation for MERCOSUR nationals * CFOs expect M&A activity to increase

November 14English | Español
US midterm elections may impact future tax reform -- Mexico publishes new guidelines for the issuing of visas -- Costa Rica’s new withholding requirement on credit and debit card payments effective 1 December 2014 – Listen to OECD’s Pascal Saint-Amans keynote address at EY International Tax Conference

November 7English | Español
Major developments in global automatic exchange of information * Mexican Tax Authorities issue requirements for monthly reporting of transactions for 2014 * OECD releases BEPS discussion drafts on PE avoidance, low value-adding intra-group services * Canadian Government tables Extractive Sector Transparency Measures Act * Uruguay issues new tax credit certificate regulations, extends due date for nonresident entities to file return with Central Bank, and commits to implementing automatic exchange of tax information in 2017

October 2014

October 31English | Español
OECD Forum on Tax Administration Communique signals enhanced global tax coordination * Canadian bill on insurance swaps and offshore banking arrangements moves forward * Colombia removes Panama, Barbados and others from tax haven list * Uruguay enacts laws for dissolving noncompliant companies, for preventing foreign states from owning rural real estate or agricultural exploitations in the country

October 24English | Español
Mexico publishes regulations on deductibility of pro rata expense allocations by NRs to Mexican taxpayers * Brazilian ruling addresses FX exchange transactions tax on conversion of foreign loans into equity * Costa Rica to enact changes to WH tax rules on interest payments abroad * Canada amends TLRE rules for commercial investment fund industry * Ecuador imposes new tax on certain credit transactions * Uruguay approves restriction on Corporate Income Tax investment exemption

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