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 2016

October 24English | Español
Final and temporary US Section 385 debt/equity regulations narrow scope of earlier proposed regulations * US taxpayers seeking unilateral APAs with Mexico for maquiladoras will not be subject to double taxation if certain conditions met * Brazil amends rules on taxation of capital gains earned by nonresidents and cross-border payments related to rental or lease of aircraft * Argentina-Chile tax treaty enters into force * EY launches Worldwide Digital Tax Guide

October 10English | Español
Puerto Rico issues guidance on application of AMT to 2015 and 2016 * Chile’s Congress sends bill to promote productivity to Constitutional Court * Canada releases proposed amendments to principal residence exemption rules for trusts and NRs * Canada's proposed legislative amendments may tax cross-border notional cash pooling arrangements * Ecuador establishes procedures for automatic application of tax treaty benefits * US IRS rules inbound asset reorganization in which a US corporation acquires substantially all of transferred corporation's assets terminates GRA * EY survey reveals increasing tax audit presence driven by BEPS * Introducing EY's 2016 Worldwide Capital and Fixed Assets Guide

October 3English | Español
Puerto Rico's new electronic unified system, SURI, to go live 1 November 2016 * Canada Revenue Agency treats certain US partnerships as corporations * Finance Canada releases draft income tax technical amendments * Costa Rica issues transfer pricing information return regulations * Latest update on OECD’s BEPS project available

September 2016

September 26English | Español
Uruguay considers bill to increase taxes * Brazil eliminates retroactive effective date for lists of low-tax jurisdictions / privileged tax regimes * Costa Rica publishes draft resolutions on new electronic voucher system * Honduras extends filing date of Monthly Purchases Sales Tax Return

September 19English | Español
Mexico to begin e-audits during September 2016 * Brazil updates lists of low-tax jurisdictions / privileged tax regimes * Mexico’s proposed 2017 tax reform includes provisions affecting oil and gas industry * Argentine Congress approves tax treaty with Chile * Costa Rican Congress approves ‘Law Against Tax Fraud’ * Peruvian Tax Authority issues ruling on legal personality of branches * Chile-South Africa tax treaty enters into force

September 12English | Español
Puerto Rico's corporate AMT ruled unconstitutional * Costa Rica’s High Court rules Tax Code Section 144 on payment of additional taxes unconstitutional * OECD releases Discussion Draft on hybrids and branch structures * Costa Rica-Germany tax treaty in force * Uruguay adopts Convention on Mutual Administrative Assistance in Tax Matters

August 2016

August 29English | Español
US issues final rules on 2% tax on payments US government makes to foreign persons under certain contracts * Peruvian Tax Authority requires resident trustees to report foreign trust information * Costa Rica establishes BEPS Commission * Spanish authorities characterize Brazilian Juros as 'interest' for treaty purposes

August 22English | Español
Canada releases consultation on GST/HST treatment of certain limited partnerships, investment plans * Uruguay proposes to adopt Convention on Mutual Administrative Assistance in Tax Matters * Latest update on OECD’s BEPS project available * EY's 2016 Worldwide Estate and Inheritance Tax Guide available

August 15English | Español
Canada introduces CbC reporting legislation * US focusing on FATCA IGAs currently 'in effect' * Colombia issues list of international stock exchanges suitable for purposes of Article 12-1 * Uruguay’s Executive Power proposes bill on fiscal transparency * Uruguay issues guidance on the import and export of samples * EY report analyzes policy perspectives of US presidential candidates

August 8 English | Español
Canada Finance releases draft legislation for 2016 budget measures and draft proposals relating to taxation of switch funds and linked notes**Argentina issues regulations on voluntary disclosure regime, new tax settlement plan and benefits for compliant taxpayers**Argentina begins bidding process for its renewable energy sources promotional regime**Canada releases draft GST/HST amendments to pension plans and master trusts**US House Republicans’ tax reform blueprint – EY article discusses five key takeaways**Latest update on OECD’s BEPS project available

August 1 English | Español
Argentina eliminates 10% dividend W/H tax, establishes voluntary disclosure regime and new tax settlement plan * Uruguay formally proposes tax increases

July 2016

July 25 English | Español
Chile publishes guidance on 2014 Tax Reform and 20215 Simplification Law ** Mexican Supreme Court declares certain electronic accounting requirements unconstitutional, upholds others ** Costa Rica issues draft transfer pricing regulations ** Costa Rica establishes guidelines for monitoring Free Trade Zone companies ** Panama expresses interest in joining Multilateral Convention on Mutual Administrative Assistance in Tax Matters ** Costa Rica approves Tax Information Exchange Agreement with Ecuador ** EY survey highlights private equity interest in oil and gas sector

July 18 English | Español
OECD releases discussion drafts on profit splits, attribution of profits to PEs * Costa Rica outlines requirements for filing certain information with tax authorities * Costa Rica-Colombia FTA effective 1 August 2016 * Uruguay approves tax treaties with Belgium and Vietnam * OECD’s Pascal Saint-Amans shares details of new long-term G20 tax project * EY BEPS 2016 mid-year review available (January–June 2016) EY report reviews global taxation of IP

July 11 English | Español
US IRS releases final regulations on CbC reporting * Argentine Congress approves bill eliminating 10% dividend W/H tax, establishing voluntary disclosure regime and new tax settlement plan * OECD releases additional Guidance on implementation of CbC reporting * Mexican Supreme Court postpones ruling on constitutionality of electronic accounting obligations * US releases proposed Qualified Intermediary Agreement

June 2016

June 27 English | Español
UK votes for Brexit; major consequences including for taxation * Mexican Supreme Court to decide constitutionality of electronic accounting obligations soon * US Tax Court imposes proper arm’s length allocation method in transfer pricing case * US, Luxembourg announce agreement to implement change to 1996 tax treaty * Canada: Revenu Québec implements new mandatory certificate for personnel placement agencies and subcontractors * OECD clarifies CRS for managed investment entity in non-CRS jurisdiction * Latest update on OECD’s BEPS project available (20 June)

June 20 English | Español
Ecuador enacts earthquake recovery law with temporary tax increase * Uruguay requires registration of financial statements * OECD Council approves changes to OECD Transfer Pricing Guidelines to incorporate BEPS reports * 19th edition of EY’s Shipping Industry Almanac issued

June 13 English | Español
Uruguayan Ministry of Economy announces tax increases * OECD releases discussion draft on multilateral instrument to implement tax treaty-related BEPS measures * Argentina issues more guidance on applying for promotional regime for utilization of renewable energy sources * EY Capital Confidence Barometer reports released for various Americas countries

June 06 English | Español
Puerto Rico repeals VAT * Mexican Supreme Court denies permanent injunction against obligation to keep electronic accounting records * Brazil revises tax on financial transactions * Uruguay approves tax treaty with United Arab Emirates, tax information exchange agreement with Chile * Canada: Manitoba, Saskatchewan and Northwest Territories 2016–17 budgets tabled * Latest update on OECD’s BEPS project available * New thought leadership for Middle Market compliance and reporting: Think Global * EY Canada releases latest issue of TaxMatters@EY * Transforming to a digital tax function: EY video and brochure

May 2016

May 23 English | Español
Costa Rica’s Committee on Financial Affairs endorses bill reinstating annual tax on legal entities * Brazil modifies procedures for applying to corporate taxpayer identification registry * OECD FTA agrees on BEPS implementation, digital and capacity building * EY report analyzes digital economy’s impact on indirect taxes * EY’s Global Mobility Effectiveness Survey highlights global mobility priorities for businesses * EY’s 2016 Worldwide Corporate Tax Guide available

May 16 English | Español
Puerto Rico's legislature approves bill to eliminate VAT; PR Treasury continues to issue VAT guidance * Canada issues proposals to implement OECD Common Reporting Standard * US proposed rules would require reporting by foreign-owned US disregarded entities * Six more countries sign tax cooperation agreement enabling automatic exchange of CbC reports * Canada invites views on proposed tariff elimination on certain agri-food processing inputs

May 09 English | Español
WTO’s Technical Committee on Customs Valuation approves case study on transfer pricing * US working toward allowing optional CbC reporting in 2016 * Argentina announces new measures regarding payment of debts abroad * Uruguayan proposed bill would postpone effective date for electronic payment requirement * Argentina issues guidance on promotional regime for utilization of renewable energy sources * Panama reorganizes FTZ in Colon, regulates other provisions * Ecuador's President submits proposed economic measures for earthquake recovery * US competent authority statistics show significant relief from double taxation * Canada: Newfoundland and Labrador releases transitional rules for HST rate increase

May 02 English | Español
Chile, Uruguay sign tax treaty with BEPS-related provisions * Ecuador proposes economic measures to aid in earthquake reconstruction * Latest on OECD’s BEPS project (25 April 2016) available * EY releases latest Global Capital Confidence Barometer

April 2016

April 25 English | Español
Puerto Rico issues new VAT transition rules for 1 June 2016 effective date * Ecuador’s president amends Tax Regulation, including transfer pricing rules, and proposes tax reform * Brazilian Congress fails to convert tax increase on interest on net equity into law * Canadian House of Commons tables motion to implement budget tax measures * Panama commits to implementing OECD's Common Reporting Standard as of 2018 * Uruguayan tax authorities rule VAT applies to advance payments for nonrefundable hotel stays

April 18 English | Español
Canada announces plans to combat aggressive tax avoidance and offshore tax evasion * Chile specifies how to elect to pay 32% substitute tax on accumulated profits * Canadian provincial budgets tabled for Newfoundland and Labrador, Alberta and Yukon * EY’s ‘Global digital tax developments review’ – new edition available

April 11 English | Español
US releases major regulations impacting related-party corporateinterests, inversion transactions * Honduras creates new Tax Administration * Spanish Court confirms Brazilian Interest on Net Equity payments benefit from participation exemption * Guatemala enacts new tax incentive regimes law * US issues annual APA report for 2015 * Canada’s Federal budget 2016-17 affects Canadian private company sale transactions * Brazil institutes new procedure for handling documents necessary during immigration processes

April 4 English | Español
US removes foreign tax credit restrictions for Cuba * Brazil issues procedures for special regime of taxation and foreign currency regularization – RERCT * OECD seeks input on treaty entitlement of “non-CIV” funds * EY publishes global ‘2016 Tax policy outlook’ * Special OECD BEPS edition of EY’s ‘Global Tax Policy and Controversy Briefing’ released * EY reports on state of private equity in Latin America

March 2016

March 28 English | Español
Canadian Federal budget 2016-17 tabled * Brazil raises tax rates on capital gains * Canada clarifies impact of government assistance on transfer pricing * Foreign entities without legal presence in Colombia may have 2016 wealth tax filing requirement * OECD releases electronic exchange format for Country-by-Country reporting * Quebec budget includes tax measures affecting the mining sector

March 21 English | Español
Colombian Commission issues tax reform recommendations * Canada: Quebec 2016–2017 budget introduces new tax measures * EY’s ‘TradeWatch’ reviews customs and trade developments across the Americas * EY’s latest ‘Tax Insights’ focuses on tax talent

March 14 English | Español
Puerto Rico has postponed VAT effective date * EY article explores digitization of tax administration across the Americas * OECD invites comments on discussion draft on treaty residence of pension funds * Puerto Rico delays electronic filing due date for certain flow-through entities * Canada extends Electronic Travel Authorization implementation date to fall 2016

March 07 English | Español
Puerto Rico issues VAT transition rules and proposed regulations * Canada–EU trade agreement one step closer to completion * Guatemalan Congress modifies tax incentive regimes * Ecuador modifies requirements for completing shareholders’ annex * Puerto Rico issues guidance on mandatory electronic filing requirements * Brazil will join the Apostille Treaty of the Hague Convention * EY’s ‘Indirect tax in 2016’ released

February 2016

February 29 English | Español
New US Model Income Tax Treaty released * Mexico publishes format for filing 2014 DIEMSE * OECD releases plan to establish inclusive framework for BEPS implementation * US amends tax regulations relating to foreign investment in US real property * OECD BEPS and EU Anti-Tax Avoidance Directive have implications for captive insurers * ‘2015-16 Worldwide Transfer Pricing Reference Guide’ released

February 22 English | Español
Puerto Rico issues guidance on filing income tax returns for large taxpayers * Argentina establishes new permanent installment plan for settling tax debts * Uruguay allows installment payments for increased amount of CIT * Argentina eliminates export duties on several mining industry products * Canada: Ontario unveils details of retirement pension plan * Canada: British Columbia budget 2016-17

February 15 English | Español
US President Obama's FY 2017 Budget builds on previous international tax proposals * Chile's Law to simplify income tax system enters into force * US Trade Facilitation and Trade Enforcement Act of 2015 expands drawback opportunities * Tax credits for VAT generated in 2012 are expiring soon in Guatemala

February 08 English | Español
Chile's Congress approves bill simplifying income tax system * Uruguay issues six tax-related decrees, enacts budget * Lower chamber of Mexico's Congress approves SEZ bill * Guatemala publishes annex to income tax return on related parties * Canadian draft proposals would modify tax treatment of certain trusts and their beneficiaries * Nicaragua delays effective date for transfer pricing rules * Honduras extends deadline for filing Annual Transfer Pricing Informative return

February 01 English | Español
31 countries sign tax cooperation agreement for automatic sharing of CbC reporting information * Venezuela publishes three important tax decrees * Puerto Rican officials informally share information about upcoming VAT * Brazil approves amnesty program for undisclosed overseas assets * Chile, Japan sign tax treaty * Guatemala proposes bill modifying tax incentive regimes * Mexico, Spain sign new protocol to tax treaty * Costa Rican Congress approves Tax Treaty with Germany * Honduras enacts new tax amnesty program * Canada implements new travel restrictions as of 15 March 2016

January 2016

January 22 English | Español
Chile considering amendments to bill simplifying income tax system * Mexican Authorities issue rules for 2016 related to FATCA and CRS reporting * Chile modifies sworn statement requirement for obtaining tax treaty benefits * Ecuador establishes requirements for completing the ‘shareholders' annex’ * Argentina establishes rules for adoption of OECD's Automatic Exchange of Financial Information in Tax Matters * Canadian Employer Certification now available for NR employers with NR employees working in Canada * OECD BEPS final reports have implications for sovereign wealth and pension funds

January 15 English | Español
Argentina to relax controls on FX market and foreign trade * Chile creates new sworn statement linked to BEPS Actions * US legislation has implications for certain foreign pension funds and FIRPTA * Uruguay issues decree on inclusion of fiscal inflation adjustments in calculating CIT * Argentina updates list of “cooperators” for tax purposes * Argentina, Belgium Social Security Totalization Agreement in force

January 08 English | Español
Puerto Rico announces two-phase implementation for VAT beginning 1 April 2016 * US issues proposed regulations on country-by-country reporting * Mexico publishes rules on investments made by foreign pension and retirement funds * Chile's Executive Branch proposes bill to simplify new income tax system * Brazil places Dutch holdcos without 'substantial economic activity' back on list of privileged tax regimes * Jamaica introduces transfer pricing rules * Uruguay adds benefits for some investment project regimes * Venezuela publishes tax treaty with Saudi Arabia

December 2015

December 18 English | Español
Argentina elects new President * Brazilian STJ exempts payments of services to Spain from Brazilian withholding tax * Impeachment proceedings begun against Brazil’s president * Canada amends taxation of investment income earned through private corporations* Guatemala’s Executive Branch signs Credit Card Law * El Salvador reduces withholding rate on investments in certain securities * OECD releases 2014 Mutual Agreement Procedure statistics

December 11English | Español
Brazilian Congress rejects tax-planning disclosure requirements – Detailed review of forthcoming US Treasury regulations to affect certain inversion transactions – Brazilian visa exemption law approved for upcoming Olympic Games -- Canadian federal personal income tax changes released

December 04English | Español
Argentina elects Mauricio Macri as new President; policy changes expected * Final OECD BEPS reports impact documentation, structure of cross-border employment activity * Pending US Treasury regulations will limit benefits of certain post-inversion transactions * US Congressional Tax Committees hold BEPS Hearings

November 2015

November 20English | Español
Mexico amends Administrative Tax Rules for investments by foreign pension and retirement funds in Mexico * Mexico’s 2016 tax reform published in the Official Gazette * Argentina adds new benefits, extends promotional regime for renewable energy sources * EY releases new tax transparency report for multinational businesses * EY Canada releases latest issue of TaxMatters@EY

November 13English | Español
OECD publishes consolidated ‘International VAT/GST Guidelines’ * Argentina sets new installment plan for settling tax debts * El Salvador's Congress approves special tax of 5% on annual net income for large taxpayers * Argentina, Mexico sign new tax treaty * US Senate Foreign Relations Committee approves eight tax agreements; further action uncertain * President Obama releases text of Trans-Pacific Partnership, sets in motion Congressional action * All Canadian permanent residents will require PR Cards to return to Canada from international airports

November 06English | Español
Mexican Senate, Lower Chamber approve tax reform for 2016 * Panama expands withholding mechanisms for VAT * Sao Paulo changes tax basis calculation of ICMS for software sales * Argentina–Switzerland Tax Treaty enters into force

October 2015

October 30English | Español
Costa Rican taxauthorities only to require audited financial statements from large taxpayersupon request * El Salvador's Congress approves expansion of tax incentives for renewable energy * Canada-Spain tax protocol entering into force in December 2015 * Canada: Alberta issues budget 2015–16 * Latest update on OECD’s BEPS project available

October 23English | Español
More EY Tax Alerts available on final OECD BEPS reports * Chile concludes tax treaty negotiations with Italy and Japan * Honduras enacts Social Protection Law * Canadian online employer portal for foreign worker employment offers coming next week * EY’s 2015-16 ‘Worldwide Personal Tax Guide’ now available

October 16English | Español
Detailed EY Tax Alerts now available on final OECD BEPS reports * Trans-Pacific Partnership countries reach agreement on trade agreement terms * Uruguay Budget proposes significant tax changes * Honduras issues new transfer pricing regulations * El Salvador publishes revised list of tax havens * Puerto Rico approves technical amendments to SUT and new VAT

October 09English | Español
OECD issues final BEPS reports * Brazil considers changes to taxation of interest on net equity payments * Panama amends procedures to secure Double Tax Treaty benefits * Canadian Administrative Monetary Penalties for Employers coming December 2015 * Honduras approves municipal tax amnesty program * Costa Rica revises income tax brackets for 2016

October 02English | Español
Brazil announces new tax measures to reduce deficit * Details available on new Brazil-US FATCA agreement * Canada implementing new Electronic Travel Authorization for visa-exempt foreign nationals * Latest update on OECD’s BEPS project available - Final BEPS deliverables set for 5 October release

September 2015

September 25English | Español
Ecuador issues regulations on requesting increased deduction limit for certain expenses * Peru approves regulations for requesting private letter rulings * New Spanish participation exemption rules do not apply to Brazilian Interest on Net Equity payments * Natural Resources Canada releases extractive sector transparency reporting guidance * New EY report looks ahead to tax, business and policy implications of 3D printing

September 18English | Español
Mexico’s latest tax reform plan could significantly affect energy sector * Peru enacts tax changes that temporarily exempt certain transfers of shares from CGT * Final OECD BEPS reports will be released 5 October *Argentina extends Employment Promotional Regime

September 11English | Español
Mexico's President submits 2016 tax reform package * Mexican Tax Authorities focus on enforcement of 2014 Tax Reform * Brazil likely to continue focusing on revenue despite withdrawal of proposed tax increases * Peruvian President proposes exempting certain transfers of shares from CGT * Brazil postpones new disclosure requirement for certain tax-planning structures for 2015 * Peru promotes investment in real estate investment trusts

August 2015

August 28English | Español
Costa Rican bills would replace Income Tax Law, substitute current Sales Tax Law with VAT * Honduras extends tax amnesty program * Canada releases annual APA and MAP program reports * EY Report: Lessons learned from Mexico’s first round of oil rights bidding

August 21English | Español
Puerto Rico passes final step towards VAT implementation * Chile’s IRS issues instructions on anti-avoidance rules * Brazil considers increased taxation for financial firms, interest on net equity * US IRS publishes final guidance on obtaining APAs and competent authority assistance * Latest update on OECD’s BEPS project available

August 14English | Español
OECD issues two new reports on implementation of Common Reporting Standard, updates global voluntary disclosure publication**US Tax Court holds that stock-based compensation costs should not be included in the cost pool for QCSAs subject to the 1995 cost-sharing regulations**Canada clarifies tax withholding obligations for nonresident employers with frequent business travellers to Canada**Canada–India Social Security Agreement enters into effect

August 7English | Español
Ecuador's new regulations address transfer pricing documentation requirements*Chile issues guidance on statement required to benefit from a tax treaty*Canadian Finance releases draft legislation for 2015 budget and resource-related tax measures*US ‘innovation box’proposalreleased*Puerto Rico reinstates requirement for merchants to electronically file monthly Sales and Use Tax returns*Latest update on OECD’s BEPS project available*Uruguayan tax authorities set deadlines to apply for fiscal electronic documents’ regime*

July 2015

July 31English | Español
Chile's IRS publishes last instructions on 2014 Tax Reform * OECD outlines membership process for Costa Rica * Peruvian tax authority issues notice on certificates of residence

July 24English | Español
Brazil announces settlement program and new disclosure obligations * Brazil, United States sign social security agreement * EY’s Latest update on OECD’s BEPS project available * EY publishes 2015 ‘Global Oil and Gas Tax Guide’

July 17English | Español
Brazil expected to raise taxes on financial institutions, high net worth persons * Brazilian authorities rule on cross-border payments under Brazil-France tax treaty * Uruguay considers modifying rules for Free Zones * US, Vietnam sign first income tax treaty * Uruguay modifies rules for depreciating intangible assets * OECD holds final public consultation on BEPS Actions 8-10 on transfer pricing

July 10English | Español
Greek crisis: Eurozone withdrawal and introduction of new currency would create tax issues * Chile enacts Direct Foreign Investment Framework Act * Panama amends its income tax regulations and addresses recent concerns regarding definition of Panamanian-source income * World Customs Organization publishes guide to customs valuation and transfer pricing * Chile and China sign tax treaty

June 2015

June 26English | Español
Details available on OECD’s CbC implementation package under BEPS Action 13 * Colombia's Central Bank requirements deadline 30 June 2015 * Tax Court of Canada rejects mark-to-market accounting for option contracts * Mexican authorities publish revised version of Appendix 9 of Multiple Disclosure Return * Federal Court of Canada upholds CRA's request for tax working papers

June 19English | Español
Honduras amends 2014 Tax Reform * Costa Rica's transition period following repeal of W/T exemption on interest payments to non-domiciled banks and financial entities expired * El Salvador signs OECD’s Multilateral Convention on Mutual Administrative Assistance in Tax Matters * Canada changes policy for approval of customized forms * EY’s Managing indirect tax controversy’ publication released * EY issues ‘2015 Worldwide Cloud Computing Tax Guide’

June 12English | Español
Puerto Rico enacts income tax, other changes in FY 2016 budget * Canada's proposed changes to anti-avoidance rule may impact internal reorganizations * OECD releases discussion draft on hard-to-value intangibles under BEPS Action 8 * Canada and China sign social security agreement * New EY Colombia Oil and Mining Bulletin issued

June 5English | Español
Puerto Rico adopts VAT system * Brazil amends PIS/COFINS for FX gains, certain hedge transactions * Canada’s ‘Extractive Sector Transparency Measures Act’ in force * Costa Rica amends Tax Code to facilitate implementing exchange of information * Argentina, Chile sign new tax treaty * Chile-UK Totalization Agreement in force 1 June 2015

May 2015

May 29English | Español
US proposes revisions to model tax treaty * Puerto Rico VAT again before legislative assembly * Chile issues instructions on passive income taxation regime * Panama enacts new penalties for noncompliance with corporate record-keeping * Ecuador enacts tax amnesty * Brazil adopts new procedure for filing Visa Transformation applications

May 15English | Español
Panama enacts tax reform * Brazil requires entry within one year of visa issuance * Latest on OECD BEPS project available * EY survey reveals how family businesses succeed in the world economy

May 8English | Español
Puerto Rican tax reform bill narrowly defeated in House of Representatives*OECD proposes significant changes to guidance on cost contribution arrangements*Canada’s federal budget proposes denying deduction in ‘synthetic equity arrangements’*Manitoba budget 2015–16 introduced*Newfoundland and Labrador budget 2015–16 introduced*EY’s '2015 Worldwide Corporate Tax Guide' now available*EY’s '2015 Worldwide VAT, GST and Sales Tax Guide' now available

May 1English | Español
Brazilian Federal Police investigate suspected corruption at Brazil's Administrative Council of Tax Appeals *New Colombian wealth tax may apply to foreign entities without legal presence in Colombia*Argentina establishes new installment plan for settling tax debts*Panama accelerates deadline for complying with custody regime for bearer shares*El Salvador's Supreme Court declares minimum income tax on net assets unconstitutional*Canada’s Budget 2015 would expand FAPI computation under captive insurance arrangements*Buenos Aires city and province update turnover tax withholding systems for nonresidents*Argentine tax authorities extend electronic invoicing system to all VAT taxpayers*Welcome news for charitable sector included in Canadian Budget 2015 *Ontario Budget 2015–16 tabled*Latest update on OECD’s BEPS project available

April 2015

April 24English | Español
Canada issues Federal Budget 2015–2016 * Argentina, Chile sign new tax treaty * Peru amends rules on financial derivatives and indirect transfers of Peruvian shares * Large Brazilian companies must publish financial statements in Official Gazette * OECD issues discussion draft on economic analysis of base erosion and profit shifting under BEPS Action 11 * US IRS issues competent authority statistics * Netherlands, Curaçao publish amended draft for new tax treaty

April 17English | Español
Mexican authorities update draft of Second Amendments to 2015 Temporary Tax Regulations * Brazil increases PIS COFINS rates computed on financial income * As Puerto Rico prepares to become a VAT jurisdiction, assessing impact becomes a business imperative * Latest update on OECD’s BEPS project available

April 10English | Español
Mexican Tax Authorities grant new extension for electronically filing Form 76 * OECD issues discussion drafts on BEPS Action 12 - mandatory disclosure rules, and BEPS Action 3 - strengthening CFC rules * Uruguay–Switzerland Social Security Totalization agreement in effect

April 3English | Español
Costa Rica proposes to replace General Sales Tax Law with VAT * Peru approves law to promote R&D * Peru determines MFN clause in DTTs applies only to Canada and Mexico * Three Canadian provincial budgets tabled: Quebec, Alberta, New Brunswick * OECD holds public consultation on BEPS Actions 8-10 on transfer pricing * US IRS issues annual APA report for 2014 * Uruguay's new Customs Code in force * Puerto Rico Governor approves tax amnesty program, temporary periods to pay at special tax rates

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 04English | 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