17 January 2014
Americas Tax Center Weekly Roundup
Latest news — Americas
Colombia issues regulation on effective place of management for companies and foreign entities
Colombia’s Ministry of Finance and Public Credit has issued a decree regulating the concept of effective place of management for companies and foreign entities. This is an important change in the Colombian tax system, which traditionally followed the concept of incorporation of the company or legal entity in Colombia to determine the tax consequences in the country. The decree establishes that, when a company has its effective place of management in Colombia, it will be considered as a national and will be treated as similar to a Colombian entity. A Tax Alert has details.
Argentina imposes new income tax collection system on triangular exports
The Argentine Federal Tax Authorities (AFIP) have issued General Resolution 3577/2013 (published in the Official Gazette on 7 January 2014), creating an income tax collection system applicable to Argentine exports whereby the country of destination for the goods differs from the country to which the goods are invoiced (triangular exports). The amount to be collected shall be calculated at the 0.50% rate over the FOB (free on board) value of the export (2% for invoices issued to parties in deemed "non-cooperative" countries). A Tax Alert has details.
Canada–EU agreement will impact mining and energy products sector
With the Comprehensive Economic and Trade Agreement (CETA) agreed to in principle by the executive branches of Canada and the EU, new trade and supply chain opportunities for importers, exporters and investors in the mining and energy products sector will materialize. Although it may take a few years for CETA to come into force, as every Canadian province and EU member state will have to ratify the agreement, provisional market access liberalization measures could come into force much sooner. A Tax Alert has details.
EY's Indirect Tax Briefing highlights recent indirect tax developments around the world
The January 2014 issue of EY’s Indirect Tax Briefing is now available. In addition to the regular snapshot overview of recent and upcoming indirect tax changes around the globe, this issue contains articles focusing on indirect-tax-issue perspectives from the worldwide cloud computing survey, and business and tax considerations related to global carbon regimes. Country updates address, among other topics, an update on the Canadian "iPod tariff" and amendments to Mexican indirect tax laws impacting foreign trade operations.
Canadian tax publication discusses stock options in the course of restructurings
Tax Intelligence, a series prepared by the Couzin Taylor law firm allied with EY Canada, covers significant topics and developments in Canadian tax law and administration that impact businesses and taxpayers in Canada and beyond. The latest issue focuses on the deductibility of amounts paid by employers in accordance with their established stock option plan in the specific course of a corporate reorganization, citing relevant jurisprudence from past Canadian court decisions.
Latest Brazilian Capital Confidence Barometer now available
Our latest Capital Confidence Barometer (CCB) shows Brazil remains one of the top five global investment destinations, as increasing global confidence and deal fundamentals may signal a return of global deal activity. But Brazilian executives show a fundamental shift in how they view the global economy versus their own. Our recently-released Brazil-focused CCB report looks at the economic outlook in the country, access to capital, growth strategies, and mergers and acquisitions.
This week's tax treaty news in the Americas
- Ecuador and China: tax treaty ratified
This week’s EY Global Tax Alerts
- Russia adopts tax initiatives to improve the taxation regime of financial transactions (15 January 2014)
- Austria publishes draft bill 2014 amending Tax Acts (15 January 2014)
- Argentina imposes new income tax collection system on triangular exports (15 January 2014)
- Vietnam releases circular on treaty benefit application (14 January 2014)
- Colombia issues regulation on effective place of management for companies and foreign entities (13 January 2014)
- Hong Kong proposes 8.25% tax rate for captive insurers (10 January 2014)
- US IRS issues final, temporary and proposed regulations on determining PFIC ownership and annual filing requirements for PFIC shareholders (10 January 2014)
- Italy publishes draft annual return and instructions for financial transaction tax (9 January 2014)
- Puerto Rico extends deadline for requesting partial waiver from additional tax on gross income to 31 January (9 January 2014)
- Panama creates a withholding tax applicable to factoring agreements (9 January 2014)
- Belgium enacts new tax laws (8 January 2014)
- Mexico tax reform: VAT certification for multinational corporations with manufacturing operations (21 January)
Beginning 1 January 2015, Mexican imports covered under a temporary regime will be taxed at the 16% general VAT rate and at the applicable rate under Excise Tax Law provisions. However, under both VAT Law and Excise Tax Law provisions, companies that obtain a "VAT/Excise Tax Certification" may get a credit equivalent to 100% of the applicable VAT or excise tax, provided that such certification is obtained prior to 1 January 2015. An upcoming webcast will cover the progressive benefits, requirements and obligations that Mexican taxpayers should observe and comply with, in order to obtain this certification. Register here.
- 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.
EY industry, service and issue publications
- EU FTT -The tiny tax with global ramifications. Are you ready? Industry survey 2013
- Transforming the bank: regulation and strategy
- You could be under cyber attack — now
- Privacy trends 2014: Privacy protection in the age of technology