3 January 2014
Americas Tax Center Weekly Roundup
Latest news — Americas
Mexico’s President issues decree granting tax incentives to maquiladoras
On 26 December 2013, following up on the tax reform passed earlier in the month, Mexico’s President Pena Nieto published a decree granting tax incentives to the manufacturing, maquiladora and export services industry in the Official Gazette. The decree provides some guidance and relief with respect to changes in the laws that will go into effect on 1 January 2014. In addition, on 30 December 2013, the Mexican tax authorities issued clarifying rules related to certain items included in the tax reform relevant for maquiladoras. A Global Alert provides details.
New Argentine tax compliance obligations address transactions between local related parties
The Argentine Federal Tax Authorities (AFIP) have issued General Resolution 3572 (published in the Official Gazette on 19 December 2013), creating obligations related to transactions performed between local related parties. Argentine corporate resident taxpayers – including companies, Argentine branches and certain trusts – must register in the new "Related Parties Register" whenever they are related to other entities located in Argentina or abroad. The same entities will also have to comply with a monthly informative system for transactions performed in the Argentine market with local related parties. A Tax Alert has details.
Peru approves treaties with Portugal, Korea, Switzerland and Mexico
On 27 December 2013, the Peruvian Parliament submitted Legislative Notices No. 30140 and No. 30141, approving tax treaties with Korea and Portugal. The next day, 28 December 2013, the Peruvian Parliament submitted Legislative Notices No. 30143 and No. 30144, approving tax treaties with Switzerland and Mexico. The notices have been published in the Official Gazette. The treaties specify withholding tax rates and generally follow the OECD Model with slight variations. Separate Tax Alerts have details on the Portugal and Korea treaties and the Switzerland and Mexico treaties.
Argentina-Spain tax treaty enters into force
As published in the Official Gazette on 24 December 2013, the Argentina-Spain Tax Treaty signed on 11 March 2013 entered into force on 23 December 2013. Article 28 of the Treaty indicates that the treaty applies retroactively to 1 January 2013. The new treaty includes a number of changes from the previous treaty that was applicable through the end of 2012. A Tax Alert has details.
This week's tax treaty news in the Americas
- Barbados and Malta: tax treaty protocol ratified
- Bermuda and US: FATCA agreement details available
- Canada and France: tax treaty protocol ratified
- Ecuador and Qatar: tax treaty authorized for signature
- Guatemala and World Trade Organization: Guatemala signs agreement to abolish certain tax incentives and exemptions
This week’s EY Global Tax Alerts
- Peru approves treaties with Switzerland and Mexico (31 December 2013)
- French Finance Bills finally enacted but certain provisions censored by the Constitutional Court (30 December 2013)
- Peru approves treaties with Korea and Portugal (30 December 2013)
- Mexico's President issues Decree granting tax incentives to maquiladoras (30 December 2013)
- Spanish 2014 Budget Law extends increased tax rates for non-Spanish residents and amends exit tax rules (27 December 2013)
- Hong Kong Financial Services Development Council issues proposal on private equity funds (26 December 2013)
- Dutch Supreme Court asks CJEU to address EU compatibility of Dutch dividend taxation of French bank (24 December 2013)
- EU Savings Directive reform timeline delayed but Swiss announce intent to negotiate revised EU agreement (23 December 2013)
- Swiss Federal Council presents final report regarding Corporate Tax Reform III (20 December 2013)
- Argentine Tax Authorities issue new tax compliance obligations regarding transactions between local related parties (20 December 2013)
- Angola requires transfer pricing documentation for 2013 transactions (20 December 2013)
- France’s Parliament approves 2014 Finance Bill and Amended 2013 Finance Bill (20 December 2013)
- Japan and UK sign protocol amending the tax treaty (20 December 2013)
- Georgia's Ministry of Finance issues transfer pricing instruction and documentation requirements (20 December 2013)
- Argentina publishes law approving Argentina-Spain Tax Treaty (19 December 2013)
- Cloud computing – a global perspective (23 January)
Does your organization understand its global tax risks surrounding cloud-based transactions, and how the cloud tax landscape may change in the coming months and years? We invite you to join our panel of tax professionals for an informative and multinational discussion regarding the cross-border tax considerations for global cloud computing arrangements. Whether you are a cloud user or cloud service provider, this webcast will help you understand the relevant tax issues and opportunities. Register here.
Recently archived webcasts now available on-demand
- Brazil's broad tax changes – what you need to know now!
On 12 November 2013, Brazil’s Executive Branch published Provisional Measure 627 containing a broad array of tax changes that will affect multinational companies doing business in Brazil as well as Brazilian multinationals with operations abroad. Taxpayers need to decide, based on their specific facts and circumstances, whether to adopt the sweeping changes for fiscal year 2014. A recent webcast discussed the new tax rules and the circumstances where early adoption of the newly issued tax rules may be beneficial. Register here.
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