Tax Services

  • Share

Tax Policy Dispatch

Untitled Document

Click on a region below for the latest legislative developments and analysis for the Americas.

EY - Map

EY - Map

EY - Map

EY - Map

Canada


Topic Description Date
Canada's Finance Minister introduces draft legislation regarding private companies Federal Finance Minister Bill Morneau introduced draft legislation, explanatory notes, and a consultation paper proposing to fundamentally overhaul the system of taxation for private companies, their shareholders and family members. 31 July 2017
Canada's Finance Minister releases consultation paper and draft legislation targeting tax planning using private corporations Federal Finance Minister Bill Morneau released for consultation a paper and draft legislative proposals addressing tax planning arrangements using private corporations. 19 July 2017
Mexican Ministry of Economy creates new website to facilitate NAFTA modernization public comment process in preparation for renegotiation In accordance with the Mexican President's request to maintain a permanent public comment process to guide the North American Free Trade Agreement (NAFTA) modernization, the Ministry of Economy announced, on June 26, 2017, a new website that will serve as the mechanism for public comments on the NAFTA modernization. 06 July 2017

Proposed changes to Canada's income tax Voluntary Disclosure Program discussed

The Canada Revenue Agency released highly anticipated proposed changes to the Voluntary Disclosures Program that would narrow its application and offer less generous relief or, in some cases, no relief, to non-compliant taxpayers.

21 June 2017

Canada’s federal budget for 2017-18 contains targeted measures of interest to financial services organizations Canada’s federal Finance Minister Bill Morneau tabled his second budget on March 22. Contrary to rumors, the budget contained no increase in the capital gains inclusion rate and contained targeted tax measures of interest to financial services organizations (FSOs), namely, banks, insurers and asset managers. 24 March 2017
Canada Revenue Agency releases guidance on country-by-country reporting The Canada Revenue Agency has released its guidance on country-by-country reporting in Canada. 20 March 2017
The Mexican government initiates consultation period to receive comments in preparation for renegotiation of NAFTA President Trump has made quite clear his intention to renegotiate the North American Free Trade Agreement (NAFTA) with Mexico and Canada. To date, no official request from the US government has been made, no timetable established, and no concrete proposal for potential amendments put forward by either the US, Canada or Mexico. 06 February 2017

Taiwan-Canada income tax arrangement enters into force

An arrangement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income entered into force on December 19, 2016, and applies to the relevant taxes arising from transactions on or after January 1, 2017. 06 January 2017

Canada Revenue Agency treats certain US partnerships as corporations

The Canada Revenue Agency (CRA) will consider limited liability partnerships and limited liability limited partnerships (collectively, LLPs) established under Delaware and Florida law to be corporations for Canadian income tax purposes. The consequences are that these LLPs will be considered separate legal entities for tax purposes, taxable at the entity level rather than at the partner level. 22 September 2016
×

United States


Topic Description Date
EY Center for Tax Policy: This Week in Tax Reform for October 16 This week in tax reform provides a high-level summary of the week’s key US legislative developments in the areas of tax reform and tax policy. 16 October 2017
Tax reform 'framework' provisions would impact banking sector The framework for tax reform released by President Trump and leading Congressional Republicans includes a number of business and international provisions that would impact banks. 06 October 2017
Senate Budget Committee approves FY 2018 budget IThe Senate Budget Committee, approved an FY 2018 budget resolution with tax reform reconciliation instructions that, if the House and Senate agree to the same resolution, will allow a tax bill to pass the Senate with the votes of as few as 50 senators (with the Vice President breaking the tie). 05 October 2017
Treasury releases report on reducing regulatory tax burdens In a report on planned actions regarding eight tax regulations earlier identified as burdensome, the Treasury Department said it is considering a proposal to revoke the Section 385 documentation regulations and to develop revised documentation rules that would be substantially simplified and streamlined. 04 October 2017
Treasury intends to delay the application of final regulations under Section 987 by one year, but immediate pre-transition considerations remain for taxpayers On October 2, 2017, the US Treasury Department and the US Internal Revenue Service announced that they intend to amend the final regulations under Section 987, as well as certain related provisions of the temporary regulations under that section to delay the applicability date of those regulations by one year. 03 October 2017
Federal tax reform framework has state tax implications The Alert focuses on the US state and local (collectively, state) tax implications of the Framework. 03 October 2017
Energy considerations of newly released tax reform framework Those in the energy sector should note that the Administration and Congressional Republicans released a tax reform framework designed to simplify the US federal income tax code and lower tax rates. 01 October 2017
Tax reform framework would repeal AMT and estate tax, eliminate all individual deductions except home mortgage interest and charitable donation This Alert highlights key aspects of the framework affecting individual taxpayers. 29 September 2017
Tax reform 'framework' calls for reduced tax rates, a territorial tax system and a level international playing field The framework calls for replacing America's "existing, outdated worldwide tax system" and allow a 100% exemption for dividends from foreign subsidiaries in which the US parent owns at least a 10% stake. 28 September 2017
Eyes on US tax reform: A guide to income tax accounting considerations As US tax reform unfolds and legislation begins to take shape, it is critical that companies understand the various tax proposals and evaluate and prepare for the financial statement income tax accounting considerations associated with a potentially unprecedented shift in US taxation. 28 September 2017
Real estate industry should take note of tax reform progress with release of new framework While short on details, there are several proposals in the framework that are of interest to the real estate industry. 28 September 2017
President Trump calls 20% corporate tax rate 'perfect' President Trump has said the 20% statutory corporate tax rate included in the "Unified Framework for Fixing Our Broken Tax Code" unveiled earlier is non-negotiable and is the "perfect number." 27 September 2017
LB&I provides a qualified research expense safe harbor for research credits claimed on or after September 11, 2017 Long-anticipated examination guidance on the credit for increasing research activities under Section 41 (research credit) was released in a directive dated September 11, 2017 (LB&I-04-0917-005). 25 September 2017
QUEST Monthly Economic Update highlights key US and global economic trends — September 2017 EY's Quantitative Economics and Statistics (QUEST) group has developed a monthly publication summarizing the latest key economic and employment trends in a short, easy-to-read format. 11 September 2017
Senate approves debt limit, CR, hurricane funding bill The Senate approved a bill to extend both government funding and the federal debt limit through December 8, and provide $15.25 billion in hurricane relief funding. The House later passed the bill, which the President signed September 8. 07 September 2017
OECD releases further guidance on Country-by-Country Reporting The Organisation for Economic Co-operation and Development's Inclusive Framework on BEPS released two sets of guidance on September 6, to give greater certainty to tax administrations and multinational enterprise groups on the implementation and operation of Country-by-Country Reporting (BEPS Action 13). 07 September 2017
What's past is prologue: How previous international tax reform proposals may shape the current debate

Tax reform will have broad and significant implications for both US businesses operating globally and foreign-based businesses operating in the United States –read about how prior international tax proposals may affect key design issues.

31 August 2017
President Trump begins major push for tax reform President Trump began a major push for tax reform on August 30, 2017, highlighting how reducing tax rates and simplifying the tax code will benefit average Americans. 30 August 2017
One-year delay for implementation of certain parts of Section 871(m) regulations The Treasury and Internal Revenue Service released Notice 2017-42 extending the transition period for applying certain parts of the Section 871(m) rules. 08 August 2017
IRS delays Section 385 debt-equity documentation requirements by one year In Notice 2017-36, the IRS has delayed by 12 months the effective date of the documentation rules under Section 385. 04 August 2017
Puerto Rico enacts changes to require the deposit of sales tax on a bimonthly basis Puerto Rico has amended sections of Puerto Rico's Internal Revenue Code, including the sales and use tax provisions to require taxpayers to pay the sales tax on a bimonthly basis. 02 August 2017
Income Tax accounting considerations related to potential future US tax legislation and steps companies can take now to prepare If enacted, tax reform could have significant income tax accounting implications for US companies in the financial reporting period of enactment. 02 August 2017
OECD releases report on branch mismatch arrangements The OECD released a report, on Neutralizing the Effects of Branch Mismatch Arrangements, as part of the follow-up work under Base Erosion and Profit Shifting (BEPS) Action 2. 02 August 2017
OECD releases draft changes to be incorporated in 2017 update to OECD Model Tax Convention The Organisation for Economic Co-operation and Development has released the draft contents of the 2017 update to the OECD Model Tax Convention. 31 July 2017
US completes CbC competent authority arrangements with five additional countries The IRS recently added five countries (Belgium, Brazil, Isle of Man, Jamaica and Malta.) to the list of countries with which the US has concluded Competent Authority Arrangements for the automatic exchange of country-by-country reports, bringing the total of those agreements to 17. 28 July 2017
IRS delays Section 385 documentation requirements by one year The IRS has delayed application of the documentation regulations under the Section 385 regulations by 12 months. 27 July 2017
Senate defeats effort to repeal ACA The Senate on July 27, 2017, defeated the Republican attempt to pass H.R. 1628, the "American Health Care Act of 2017," culminating in a 49-51 vote to defeat the "skinny bill" that was the Republican's best hope to repeal the Affordable Care Act (ACA). 27 July 2017
OECD updates G20 Leaders on progress in key areas of tax work The Organisation for Economic Co-operation and Development has issued a report to the G20 Leaders updating them on progress in key areas of the G20/OECD's tax work. 21 July 2017
OECD releases update of Guidance on the Implementation of Country-by-Country Reporting The Organisation for Economic Co-operation and Development has released an updated version of its Guidance on the Implementation of Country-by-Country Reporting. 20 July 2017
Deadline approaching for certain multinational companies to request suspension of MAP-related deadline under Mexico-US income tax treaty Companies under a tax audit for tax year 2012 and onwards should request suspension of the deadline now to preserve their right to receive MAP assistance, particularly if they have not received an observation letter or tax assessment from Mexico identifying possible areas of non-compliance under the Mexico-US income tax treaty. 20 July 2017
Finance Committee questions former Assistant Secretaries for Tax Policy, current nominee The hearing included discussion of the need for anti-base erosion rules under a territorial tax system and issues related to the taxation of pass-through entities. The Committee held a separate hearing, directly after, on the nomination of David Kautter, a former Director of National Tax at EY, to be the next Assistant Secretary of the Treasury for Tax Policy. 19 July 2017
Trump Administration releases summary of NAFTA renegotiation objectives US Trade Representative (USTR) Robert Lighthizer has formally notified Congress and the public of the Trump Administration's objectives for the North American Free Trade Agreement (NAFTA) renegotiation. 18 July 2017
House Budget Committee releases FY2018 resolution The House Budget Committee released its fiscal year 2018 budget resolution that includes reconciliation instructions for deficit-neutral tax reform and for at least $203 billion in mandatory savings and reforms over 10 years. 18 July 2017
Mexico signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS Mexico and 67 other jurisdictions signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS. 17 July 2017
New IRS country-by-country reporting site offers US multinationals the latest forms and guidance The IRS recently launched a section on irs.gov dedicated to country-by-country reporting. The website provides background information on country-by-country (CbC) reporting, some frequently asked questions and other helpful resources. 11 July 2017
G20 Leaders' communiqué demonstrates continued support on tax issues, highlights new developments The G20 Leaders issued a communiqué updating progress in key areas of OECD/G20 tax work, including movement towards the automatic exchange of information between tax authorities and implementation of key measures to address perceived tax avoidance by multinational companies. 10 July 2017
Treasury identifies eight regulations under Executive Order review The Treasury Department identified eight regulations as imposing an undue financial burden on US taxpayers or adding undue complexity to Federal tax laws. 07 July 2017
OECD, UN, IMF and World Bank issue toolkit for addressing difficulties in accessing comparable data for transfer pricing analysis The "Platform for Collaboration on Tax"— a joint effort of the Organisation for Economic Co-operation and Development (OECD), United Nations (UN), International Monetary Fund (IMF) and World Bank Group (WBG) — released a toolkit designed to help developing countries address the lack of "comparables" for transfer pricing analyses and better understand mineral product pricing practices. 07 July 2017
Mexican Ministry of Economy creates new website to facilitate NAFTA modernization public comment process in preparation for renegotiation In accordance with the Mexican President's request to maintain a permanent public comment process to guide the North American Free Trade Agreement (NAFTA) modernization, the Ministry of Economy announced, on June 26, 2017, a new website that will serve as the mechanism for public comments on the NAFTA modernization. 06 July 2017

Hatch asks Finance members to focus on tax reform areas

Finance Committee Chairman Orrin Hatch (R-UT) on June 27, 2017, asserted that there will be "a robust process in the Senate for developing, considering, and passing any tax reform package" and announced that he has tasked Committee members with focusing on particular areas under tax reform.

27 June 2017

OECD releases revised discussion drafts on profit splits and attribution of profits to permanent establishments

The Organisation for Economic Co-operation and Development released discussion drafts on the revised guidance on profit splits and the additional guidance on the attribution of profits to permanent establishments.

26 June 2017

CBO & JCT release estimate of Senate GOP health bill

Agencies say ACA repeal bill would increase uninsured population by 22 million by 2026, while reducing deficit by $321 billion.

23 June 2017

Puerto Rico Secretary of Treasury extends the effective date for the obligation to remit the 1% municipal SUT on imports to Puerto Rico's Treasury Department to August 1, 2017

Puerto Rico's Treasury Department (PRTD) issued Administrative Determination (AD) 17-04 to extend the effective date for the obligation to remit the 1% municipal sales and use tax (SUT) on imports of tangible personal property from the municipality to the PRTD and to confirm that the new reporting requirements for non-withholding agent merchants are effective July 1, 2017.

23 June 2017

Senate Republicans release discussion draft of health care bill

Senate Republican leaders on June 22, 2017, unveiled a discussion draft of legislation to repeal and replace the Affordable Care Act, naming their legislation the Better Care Reconciliation Act of 2017.

22 June 2017

Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS highlights business considerations 68 jurisdictions signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) during a signing ceremony hosted by the Organisation for Economic Co-operation and Development (OECD) in Paris on June 7. 15 June 2017
OECD seeks taxpayer input on BEPS Action 14 peer reviews The Organisation for Economic Co-operation and Development (OECD) announced that it is now gathering input on the implementation of the Action 14 (Dispute Resolution) minimum standard in the third batch of jurisdictions, and invites taxpayers to submit their input by July 7. 15 June 2017
House passes Rep. Hensarling's bill repealing broad elements of Dodd-Frank Act, 233-186 No Democrats support sweeping rewrite of 2010 financial reforms; bill's chances in Senate appear slim as Sen. Crapo pursues bipartisan approach 08 June 2017
OECD releases peer review document on BEPS Action 6 on Preventing the Granting of Treaty Benefits in Inappropriate Circumstances The Organisation for Economic Co-operation and Development released the peer review document on Base Erosion and Profit Shifting (BEPS) Action 6 on Preventing the Granting of Treaty Benefits in Inappropriate Circumstances. 31 May 2017
President Trump's FY 2018 Budget cuts trillions from Medicaid, other programs over 10 Years President Trump's $4.094 trillion FY 2018 Budget blueprint, proposes to balance the budget over 10 years, spending generously on defense and infrastructure while shielding Medicare and Social Security from cuts. 23 May 2017
Puerto Rico amends sales and use tax to target collection on internet sales and the payment of municipal use tax on imports The Governor of Puerto Rico signed legislation (Act 25-2017) aimed at increasing collections of sales and use tax (SUT) on internet sales made by companies without a physical presence in Puerto Rico. 18 May 2017
Ways & Means holds hearing on growth impact of tax reform During a House Ways and Means Committee hearing on May 18, 2017, Chairman Kevin Brady (R-TX) received assurances from business leaders that full expensing of capital investments would help businesses create jobs and keep jobs in the United States. 18 May 2017
Trump Administration issues NAFTA renegotiation notice letters US Trade Representative (USTR) Robert Lighthizer has notified Congress of the Trump Administration's intent to renegotiate the North American Free Trade Agreement (NAFTA). 18 May 2017
Thune bill on cost recovery at odds with House plan Senate Finance Committee member John Thune (R-SD) on May 17, 2017, introduced a bill, for possible inclusion in a broader tax reform package, that would make permanent 50% bonus depreciation and increase small business expensing limits to $2 million annually. 17 May 2017
President signs executive order to loosen restrictions on political speech by religious entities On May 4, 2017, President Trump signed an Executive Order that directs federal agencies generally, and the Treasury Department in particular, to take "no adverse action" against any individual, house of worship or religious organization that "speaks or has spoken about moral or political issues from a religious perspective," to the extent permitted by law. 10 May 2017
Wyden introduces bill on taxation of derivatives Senate Finance Committee Ranking Member Ron Wyden (D-OR) has introduced a bill that aims to provide one set of clear rules for taxing derivatives by requiring the recognition of gains each year (mark to market) and applying ordinary tax treatment to them. 02 May 2017
Trump team seeks to clarify tax plan expectations President Trump on May 1, 2017, said the tax plan he released in April is a "starting point" and that he is willing to lose some of its provisions in negotiations with Congress. 01 May 2017
Trump's tax reform plan could hold implications for employers As it relates to individual tax reform, Trump’s proposals could have implications for employers. 27 April 2017
Trump tax plan calls for 15% business rate, territorial tax system The Trump administration has outlined a tax reform plan, that calls for a 15% business tax rate and a one-time tax on the repatriation of foreign earnings of US companies at an unspecified rate, which Treasury Secretary Steven Mnuchin said would be negotiated with Congress, along with other details. 26 April 2017
JCT projects 'Nonnegligible' out-year revenue loss for three-year corporate rate cut The chief of staff of the Joint Committee on Taxation (JCT) projected that the revenue loss for a three-year cut in the corporate tax rate to 20% would be significant and that there would be "nonnegligible" losses in the tax years immediately following the 10-year budget window. 25 April 2017
Summary and analysis of new Buy American, Hire American executive order provided President Donald Trump recently signed an executive order setting out a new “Buy American, Hire American” policy. 25 April 2017
President Trump signs executive order requiring review of tax regulations President Trump has signed an Executive Order calling for the Treasury Department to review all "significant tax regulations" issued on or after January 1, 2016, to identify those that impose undue financial burden or add undue complexity, and to recommend specific actions to mitigate the burden imposed by the regulations. 21 April 2017
OECD updates its guidance on Country-by-Country Reporting The Organization for Economic Co-operation and Development has released an updated version of its Guidance on the Implementation of Country-by-Country Reporting. 10 April 2017
New US DOL and USCIS announcements on H-1B employers examined The US Department of Labor issued statements of its intent to protect American workers from H-1B program discrimination on April 4, on the heels of an announcement from the US Citizenship and Immigration Services of measures to deter and detect H-1B visa fraud and abuse. 10 April 2017
Brexit withdrawal notification doesn't trigger immediate tax accounting consequences United Kingdom Prime Minister Theresa May gave written notice to the European Council that the UK intends to withdraw from the European Union by invoking Article 50 of the Lisbon Treaty. 30 March 2017
Puerto Rico issues order to evaluate the suspension of the granting new tax credits Puerto Rico's Financial Advisory Authority and Fiscal Agency (better known as AAFAF by its Spanish name) issued an Administrative Order that suspends the granting of new tax credits under various laws. 24 March 2017
Media & entertainment industry could see significant changes under US tax reform proposals The effects of several proposed tax reform provisions — from those addressing cross-border activities to the loss of certain deductions — could have important implications for the media and entertainment industry. 21 March 2017
US tax reform may affect an insurance company's surplus under SSAP No. 101 To the extent comprehensive tax reform legislation is enacted, insurance companies may experience significant changes in their current tax liabilities, admitted deferred tax assets (DTAs) and, ultimately, surplus. 14 March 2017
Tax landscape for retail and consumer products companies could shift under Republican tax reform proposals Tax reform proposals under consideration in Congress this year could have dramatic implications for the retail and consumer products sector. 08 March 2017
Global automotive trade could see substantial changes under US tax and trade reform Recent global political developments could mean significant changes on the horizon for the automotive industry. Potential changes in US trade positions and tax policy could intensify effects automakers are already expected to experience globally as a result of the UK's exit from the EU (Brexit). 21 February 2017
IRS relaxes individual mandate reporting The IRS has stated that it will not automatically reject Forms 1040 that fail to indicate whether the taxpayer has complied with the Affordable Care Act's "individual mandate" health coverage requirement during the 2016 tax year. 21 February 2017
US tax reform proposals could significantly affect life sciences sector In the wake of the November 2016 US elections, Republican lawmakers are planning to move forward with comprehensive federal tax reform. Life sciences companies stand to benefit from some aspects, such as proposals to lower the corporate tax rate to 20% and to allow the immediate expensing of investments. 07 February 2017
The Mexican government initiates consultation period to receive comments in preparation for renegotiation of NAFTA President Trump has made quite clear his intention to renegotiate the North American Free Trade Agreement (NAFTA) with Mexico and Canada. To date, no official request from the US government has been made, no timetable established, and no concrete proposal for potential amendments put forward by either the US, Canada or Mexico. 06 February 2017
LB&I announces first campaigns in new issue-based examination and compliance process The IRS Large Business and International Division (LB&I) has identified 13 campaigns to serve as its first focus areas under its new issue-based examination and compliance process. 02 February 2017

IRS issues guidance on Country-by-Country Reports for early reporting periods

The IRS issued guidance for the process for voluntarily filing Form 8975, Country-by-Country Report, and Schedule A, Tax Jurisdiction and Constituent Entity Information (CbC report), for reporting periods beginning on or after January 1, 2016, but before the applicability date in Reg. Section 1.6038-4 (early reporting periods).

22 January 2017

House Republicans release tax reform Blueprint

The long-awaited Blueprint on comprehensive tax reform released June 24, 2016, by the House Republican Task Force on Tax Reform proposes, among other changes, a 20% statutory corporate tax rate, a border tax adjustment mechanism, a territorial international tax system, and elimination of most business tax credits aside from the R&D tax credit.

24 June 2016

×

 

Mexico and Central America


Costa Rica

Topic Description Date
Costa Rican Tax Administration temporarily suspends filing date for transfer pricing information return The due date for filing the transfer pricing information returns for 2015 and 2016, which was set at June 30, 2017, is temporarily suspended until further notice. 09 June 2017
Costa Rican tax authorities issue new transfer pricing regulations Taxpayers should review the requirements for the master file and the local file to ensure they have complied. 17 May 2017
Costa Rica extends deadline to update electronic invoicing systems to June 15, 2017 Taxpayers have additional time to update their electronic invoicing systems to comply with Resolution DGT-R-48-2016. 21 April 2017

Costa Rican Congress enacts Law Against Tax Fraud

The Law includes new compliance procedures. Failure to comply with the new procedures may result in penalties 24 January 2017

Costa Rican Congress approves reinstatement of tax on legal entities in first vote

The Costa Rican Congress approved a bill that would reinstate, with some modifications, the annual tax on legal entities; the bill will become law upon a second approval by Congress and publication in the Official Gazette 11 January 2017

El Salvador

Topic Description Date

El Salvador tax authorities publish a revised list of tax havens for 2017

Transactions with multinational companies incorporated, domiciled or located in tax havens need to comply with the arm's-length principle. 09 October 2017
El Salvador temporarily suspends certain Tax Administration deadlines due to fire The Salvadoran Congress recently approved a 30-day suspension of legal deadlines applicable to the Tax Administration in administrative and judicial proceedings. 07 August 2017

El Salvador tax authorities publish a revised list of tax havens for 2017

Transactions with multinational companies incorporated, domiciled or located in tax havens need to comply with the arm's-length principle. Payments or amounts credited to multinational companies located in tax havens from entities domiciled in El Salvador are generally subject to an increased withholding tax rate of 25%. 13 October 2016

Guatemala

Topic

Description

Date

Guatemala abates tax fines and surcharges

Taxpayers should review the agreement and determine whether they might be able to benefit from the abatement program

19 June 2017

Honduras

Topic Description Date
Honduras enacts an entirely new Tax Code The new Tax Code shifts Honduras from a worldwide taxation system to a tax system based on territoriality. It includes new penalties and statutes of limitations, as well as an amnesty program. 17 February 2017

Honduras establishes new tax amnesty program for 2017

On December 27, 2016 Honduras published, in the Official Gazette, Decree No. 171-2016, which sets out general provisions of the Honduran General Income and Disbursement Budget for 2017, including a new tax amnesty program. 10 January 2017

Mexico

Topic Description Date
Argentina-Mexico Tax Treaty will enter into force Taxpayers should review the treaty provisions and ensure that they will be able to comply with the provisions. 14 August 2017
Deadline approaching for certain multinational companies to request suspension of MAP-related deadline under Mexico-US income tax treaty Companies under a tax audit for tax year 2012 and onwards should request suspension of the deadline now to preserve their right to receive MAP assistance, particularly if they have not received an observation letter or tax assessment from Mexico identifying possible areas of non-compliance under the Mexico-US income tax treaty. 20 July 2017
Mexico signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS Mexico and 67 other jurisdictions signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS. 17 July 2017
Mexican Ministry of Economy creates new website to facilitate NAFTA modernization public comment process in preparation for renegotiation In accordance with the Mexican President's request to maintain a permanent public comment process to guide the North American Free Trade Agreement (NAFTA) modernization, the Ministry of Economy announced, on June 26, 2017, a new website that will serve as the mechanism for public comments on the NAFTA modernization. 06 July 2017
Mexican tax authorities release draft update to list of non-binding interpretations Special purpose financial institutions (SOFOMs, the Spanish acronym) should review the interpretation on the application of the 4.9% withholding tax rate and their positions on interest paid to related parties. 11 May 2017
Mexico's Tax Ombudsman issues final transfer pricing regulations The Mexican Tax Ombudsman ha released the final transfer pricing regulations (final regulations), providing guidance on the master file, local file and country-by-country report. 18 April 2017

Mexican 2017 Budget approved with tax package

The tax package establishes new incentives and new rules for service fee payments, and makes significant changes to the value added tax (VAT). Specifically, the tax package allows taxpayers to elect how to treat VAT paid to suppliers during the pre-operating period. 21 November 2016
New OECD BEPS TP Guidelines: An analysis of possible conflict with Mexican Income Tax Law and Tax Treaties Mexican Income Tax Law automatically incorporates OECD transfer pricing (TP) Guidelines "approved by the OECD Council" in its domestic tax legislation "to the extent they are consistent with Mexican income tax law and tax treaties." This Alert analyzes whether and to what extent the new OECD TP Guidelines apply automatically in Mexico or whether a legislative change is necessary. 26 July 2016
Mexican Supreme Court of Justice declares certain electronic accounting requirements unconstitutional, validates others The Mexican Supreme Court of Justice, ruling on a case litigated by Mancera, the Mexican member of EY/Global, has issued a final decision on the constitutionality of new electronic accounting obligations, declaring certain provisions unconstitutional and validating others. 18 July 2016

Panama

Topic

Description

Date

Panama receives positive rating during the Fast Track Procedure With the upgrade from noncompliant to largely compliant, Panama has taken a positive step, which may lead to being excluded from the OECD and G20's non-cooperative list. 03 August 2017

Panama's Tax Authority extends first FATCA reporting date for Panamanian financial institutions until August 31

With the deadline pushed back from July 31, 2017, to August 31, 2017, Panamanian financial institutions will have an extra month to file their first FATCA report.

01 August 2017

Panama modifies withholding requirement established under the value added tax rules

Because of the modification to the VAT rules, new entities may be classified as withholding agents and subject to the VAT withholding requirement.

23 June 2017

Panama ratifies the OECD's Convention on Mutual Administrative Assistance in Tax Matters Panama approved the Organisation for Economic Co-operation and Development's Convention on Mutual Administrative Assistance in Tax Matters, which contains provisions for the multilateral exchange of information upon request and the automatic exchange of information. 06 March 2017

Panama ratifies the Treaty to Avoid Double Taxation signed with the Socialist Republic of Vietnam

Panama has enacted Law No. 3 of February 7, 2017, ratifying the Treaty to Avoid Double Taxation (The Treaty) and Protocol, signed with the Government of the Socialist Republic of Vietnam.

16 February 2017

Panama ratifies Exchange of Information Agreement relating to Tax Matters with Japan

Panama has ratified the Tax Information Exchange Agreement (TIEA) between the Government of the Republic of Panama and the Government of the Republic of Japan.

16 February 2017

Panama issues a policy statement regarding its compliance with fiscal transparency

Panama's Ministry of Economy and Finance issued Executive Decree No. 10 of 2017, which establishes Panama's compliance policy regarding fiscal transparency (the Policy) and sets out criteria for the country's automatic exchange of information in tax matters.

13 February 2017

Panama establishes legal framework to comply with the automatic exchange of financial information under FATCA and CRS

Financial institutions should review the provisions of Law No. 51 and implement internal policies and procedures to comply with the reporting obligations.

16 November 2016

Panama joins the Inclusive Framework on BEPS

All member jurisdictions of the inclusive framework have committed to implementing the four minimum BEPS standards: (i) harmful tax practices (Action 5), (ii) treaty abuse (Action 6), (iii) country-by-country reporting (Action 13) and (iv) dispute resolution (Action 14).

15 November 2016

Panama commits to implementing the OECD's Common Reporting Standard as of 2018 Panama's Minister of the Presidency, Alvaro Alemán, announced that Panama will start implementing the automatic exchange of financial information in accordance with the OECD's Common Reporting Standards (CRS) on a bilateral and reciprocal basis as of 2018. 19 April 2016
×

Tax policy outside the Americas


Africa

Topic

Description

Date

Estonia enacts key changes to corporate income tax rules including reduced tax rate for regular dividend payments

Income Tax Act changes have been passed in the Estonian Parliament.

23 June 2017

Estonia proposes key changes to corporate income tax rules The Estonian Minister of Finance submitted the Bill on Amendments to the Income Tax Act (the bill) for consultation on April 17. The bill aims to lower the income tax rate on regular profit distributions from 20% to 14%. 24 April 2017
Uganda issues Tax Amendment Bills 2017 Uganda’s Minister of Finance Planning and Economic Development (Minister of Finance) has tabled several tax bills before Parliament. 21 April 2017

Australia

Topic

Description

Date

Australia introduces tax bills on corporate tax cuts, small business relief, personal income tax bracket creep, budget repair, and implementation of new German DTA Australia has introduced five tax-related bills which, if enacted, will implement corporate tax rate reductions and small business tax relief, address personal income-tax bracket creep, pave the way for a new tax treaty with Germany and enact various budget savings measures. 6 September 2016

Belgium

Topic

Description

Date

Belgian Federal Government announces major corporate tax reform The Belgian Federal Government announced a major reform of the Belgian corporate tax system 28 July 2017

European Union

Topic

Description

Date

UK Tax Authorities publish response to Making Tax Digital consultations and set out draft legislation

HMRC has published a summary of feedback from the Making Tax Digital (MTD) consultation process, the Government's decisions in response, and HMRC's next steps. 09 February 2017

European Commission proposes corporate tax reform package

The European Commission announced a package of corporate tax reforms that includes three separate legislative initiatives: (i) a two-stage proposal towards a Common Consolidated Corporate Tax Base; (ii) a Directive on Double Taxation Dispute Resolution Mechanisms in the European Union; and (iii) amendments to the June 2016  Anti-Tax Avoidance Directive relating to hybrid mismatches with third countries. 25 October 2016

Estonia

Topic

Description

Date

Estonia enacts key changes to corporate income tax rules including reduced tax rate for regular dividend payments

Income Tax Act changes have been passed in the Estonian Parliament.

23 June 2017

France

Topic

Description

Date

France implements VAT law changes for 2017

The main changes to value-added tax (VAT) provisions include: (i) On-site audits; (ii) Deduction of VAT on gasoline; (iii) Import VAT reverse-charge; and (iv) Archiving of invoices. 25 January 2017

Japan

Topic

Description

Date

Japan enacts 2017 tax reform bill Japan enacted the 2017 tax reform bill (the Bill) on March 27. 30 March 2017
Japan enacts 2016 tax reform bill Japan enacted its 2016 tax reform bill, which includes a further corporate tax rate reduction, a greater limitation on annual net operating loss (NOL) deductions and a new transfer pricing documentation rule.. 30 March 2016
Japan releases 2017 tax reform outline Japan's coalition leading parties released a 2017 tax reform outline from which a tax reform bill will be prepared and then submitted to the Diet (Japanese legislature); it is expected to be enacted by the end of March 2017. 15 December 2016

India

Topic

Description

Date

India's GST is in effect as of July 1

India's comprehensive dual Goods and Services Tax (GST) has replaced the complex multiple indirect tax structure as of July 1. 07 July 2017

Korea

Topic

Description

Date

Korea announces 2017 tax reform proposals Korea's Ministry of Strategy and Finance announced the 2017 tax reform proposals that aim to create jobs, redistribute wealth and expand the tax revenue base. 18 August 2017

Luxembourg

Topic

Description

Date

Luxembourg releases broad outline of 2017 tax reform

Luxembourg’s proposed tax reform includes an amendment of the existing tax scales, tax credits and abatements for individuals and a gradual reduction of the corporate income tax rate. 01 March 2016

Norway

Topic

Description

Date

Norwegian Parliament approves 2017 Fiscal Budget

In December 2016, the Norwegian Parliament approved the 2017 Fiscal Budget in line with the Government's proposal dated October 6, 2016; the Budget, which entered into force effective January 1, 2017, includes several tax changes. 06 January 2017

Spain

Topic

Description

Date

Spain introduces new measures to increase tax revenues, including significant changes to corporate income tax

The Spanish government has introduced a number of rules aimed at increasing tax revenues. 08 December 2016

Switzerland

Topic

Description

Date

Swiss Finance Minister presents new cornerstones of tax reform

The steering body composed of federal and cantonal representatives and led by Federal Councilor Ueli Maurer set out the suggested cornerstones on the Swiss tax reform on June 1, now referred to as "Tax Proposal 17" (TP 17), on which the Swiss Federal Council will decide later in June.

05 June 2017

Swiss voters reject Corporate Tax Reform III in public referendum

Swiss voters have rejected the federal bill on Corporate Tax Reform III (CTR III) as adopted by the Federal Parliament last summer. This means that the reform will not take effect in 2019 as planned, but may be delayed by one to three years depending on the further legislative procedure.

14 February 2017

Swiss canton of Berne expresses views on implementation of Corporate Tax Reform III

The government of the Swiss canton of Berne indicated it would implement the Swiss Corporate Tax Reform III.

16 December 2016

Swiss canton of Fribourg releases plan for implementation of Corporate Tax Reform III

The Swiss canton of Fribourg presented its plan for implementing the Swiss Corporate Tax Reform III (CTR III) in cantonal tax law.

16 December 2016

Swiss Corporate Tax Reform III — National Council approves revised bill The Swiss National Council approved a revised Corporate Tax Reform III bill; the bill as amended includes elements to make the Swiss corporate tax environment more attractive and differs in several aspects from the initial version published by the Swiss Federal Council in June 2015 and the version amended by the Council of States in December 2015. 18 March 2016

Swiss canton of Basel-Land releases plan for local implementation of Corporate Tax Reform III

The Swiss canton of Basel-Landschaft disclosed its plan for implementing the Swiss Corporate Tax Reform III. 22 September 2016
Swiss canton of Basel-Stadt releases plan for local implementation of Corporate Tax Reform III The Swiss canton of Basel-Stadt presented its plan regarding the implementation of the Swiss Corporate Tax Reform III (CTR III) into cantonal tax law. 22 September 2016
Swiss canton of Geneva releases plan for local implementation of Corporate Tax Reform III The Swiss canton of Geneva presented its strategy for the implementation of the Swiss Corporate Tax Reform III (CTR III) into cantonal law and opened a consultation procedure on the proposal. 23 September 2016
Swiss canton of Zug releases plan for local implementation of Corporate Tax Reform III The Swiss canton of Zug presented its strategy to implement the Swiss Corporate Tax Reform III into its cantonal tax law. 5 October 2016
Swiss canton of Solothurn releases plan for implementation of Corporate Tax Reform III The Swiss canton of Solothurn presented its strategy to implement the Swiss Corporate Tax Reform III into its cantonal tax law. 29 November 2016

Vietnam

Topic

Description

Date

Vietnam announces tax reform proposals Vietnam's Ministry of Finance announced proposals to amend and supplement the current laws on corporate income tax, personal income tax, value added tax, special sales tax, and natural resources tax. 08 September 2017
×

South America


Argentina

Topic

Description

Date

Argentina-Mexico Tax Treaty will enter into force Taxpayers should review the treaty provisions and ensure that they will be able to comply with the provisions. 14 August 2017
Argentina and Brazil sign Amendment Protocol to income tax treaty Argentina and Brazil have signed a new protocol to the tax treaty between the countries that introduces new withholding rates, modifies certain rules, and adopts several BEPS-proposed measures, among other changes. 01 August 2017
Argentina suspends for 180 days the mechanism for nonresidents to pay capital gains tax On July 20, 2017, Argentina suspended for 180 days the application of General Resolution No. 4094-E/2017, which had established the mechanism for paying capital gains tax incurred by nonresidents. 20 July 2017
Argentina implements mechanism for non-residents to pay capital gains tax New rules specify who is responsible for withholding and paying capital gains tax incurred by non-residents, implementing changes instituted by 2013 tax reform. Foreign corporations and individuals involved in buying and selling Argentine shares or other securities, and local residents involved in such transactions, should review the new rules and take appropriate actions. 19 July 2017
Argentina signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS Argentina and 67 other jurisdictions signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS. 07 July 2017
Argentine Tax Administration accepts Supreme Court criterion on Minimum Presumed Income Tax application Based on the new criterion established by the SCJ and the General Instruction, taxpayers may not be subject to the Minimum Presumed Income Tax. 09 June 2017
Argentina enacts tax changes, including a VAT collection system for nonresidents Argentina enacted Law No. 27,346, which makes several changes to the Argentine tax regulations. 10 January 2017
Argentina and United States sign an Agreement for the Exchange of Information Relating to Taxes On December 23, 2016, Argentina and the United States signed an agreement to exchange tax information; for the United States, it applies to all federal taxes and for Argentina, it applies to all national taxes administered by the Federal Administration of Public Revenue. 9 January 2017

Argentina eliminates export duties on several mining industry products

Argentina has eliminated export duties on certain mining industry products. The Decree (Decree No. 349/2016) was published in the Official Gazette on 15 February 2016 and is effective as of its date of publication.

19 February 2016

Brazil

Topic

Description

Date

Argentina and Brazil sign Amendment Protocol to income tax treaty Argentina and Brazil have signed a new protocol to the tax treaty between the countries that introduces new withholding rates, modifies certain rules, and adopts several BEPS-proposed measures, among other changes. 01 August 2017
Brazil establishes new tax amnesty program The amnesty program is good news as it allows taxpayers to pay outstanding tax debts in installments with discounts allowed for interest and penalty amounts. 06 June 2017
Brazil amends country-by-country reporting requirements to extend July 31 deadline for filing local reports for 2016 Brazil amended its country-by-country (CbC) reporting rules to include a "transitory rule" for 2016 that provides filing relief to Brazil constituent entities whose "ultimate parent entity" is located in a jurisdiction with which Brazil does not have a qualifying competent authority agreement (QCAA) on the exchange of CbC reports. 01 June 2017
OECD releases update on CbC reporting implementation with focus on local filing in Brazil and China The Organisation for Economic Co-operation and Development provided an update on the exchange relationships to automatically exchange Country-by-Country reports. 11 May 2017
Brazilian Federal Revenue concludes remuneration from software marketing and distribution licenses should be treated as royalties Payments made abroad for a license to market and distribute software to local final consumers are royalties and are subject to a 15% withholding tax rate. 03 May 2017

Spanish Tax Administrative Court revises position and characterizes Brazilian Juros as dividends for domestic law purposes

The Spanish Tax Administrative Court issued a new decision confirming that income received by Spanish entities from Brazilian subsidiaries in the form of Brazilian Interest on Net Equity payments (juros sobre o capital proprio or JsCP) must be categorized as "dividends" for Spanish domestic tax law purposes. 21 February 2017

Brazil's Federal Revenue Agency issues Country-by-Country Reporting rules

NI 1681/2016 requires filing of the CbC report for 2016 by mid-2017, which means taxpayers should start preparing now for this reporting. Failure to comply with the CbC reporting rules could result in penalties. 05 January 2017

Chile

Topic

Description

Date

Chilean Congress to discuss new tax reform bill on BEPS, CRS and preferential regimes The bill would extend the deadline for the ratification of tax treaties to allow shareholders more time to use the entire corporate income tax as a credit against their withholding tax paid under treaties not yet in force. 06 September 2017
Tax treaties signed by Chile entered into force on January 1, 2017 On January 1, 2017, most of the new double tax treaties signed by Chile became effective (except for Uruguay). All of these treaties follow the guidelines of the model drafted by the Organization for Economic Co-operation and Development (OECD). 24 March 2017
Chile establishes country-by-country reporting Taxpayers must file Sworn Statement No. 1937 on or before the last business day of June 2017. Failure to file Sworn Statement No. 1937 could result in penalties. 05 January 2017
Chile and Uruguay sign Convention for the Avoidance of Double Taxation The new treaty provides many benefits for taxpayers, including reduced tax rates on certain capital gains and the possibility to apply reduced tax rates on dividends under local law. 27 April 2016

Chile creates new sworn statement linked to BEPS Actions

In several resolutions, the Chilean IRS created new sworn Statement (SS) No. 1913, Global Taxpayers Characterization, and revised SS No. 1851, Foreign Direct Investment, as a first step in implementing the OECD’s BEPS provisions.

7 January 2016

Ecuador

Topic

Description

Date

Ecuador's tax authority amends income tax withholding rates Taxpayers should review the new withholding tax rates on gains from the transfer of shares in the Ecuadorian stock market to ensure the correct amount is withheld. 14 September 2017
Ecuador's tax authority amends tax havens list

Ecuador's Internal Revenue Service has amended the tax haven list; Hong Kong was added to the list.

23 August 2017

Colombia

Topic

Description

Date

Colombia enacts rules for the implementation of BEPS Action 13 Colombia has enacted a tax change that makes substantial changes to the current tax legal framework, including changes in the levels of transfer pricing documentation.

22 February 2017

Peru

Topic

Description

Date

Peru enacts new bank secrecy provisions and implements tax reform

The new bank secrecy provisions will allow Peru to satisfy the international standards required by the Organization for Economic Co-operation and Development (OECD), and the tax reform extends the scope of the real estate investment trust tax regime to trusts and may reduce the value added tax.

11 January 2017

Peru amends transfer pricing rules

The Legislative Decree expands the transfer pricing documentation requirements to include the country-by-country report, local file and master file proposed by the OECD under BEPS Action 13. Taxpayers should prepare now to implement this new reporting.

06 January 2017

Peru enacts tax reform Beginning January 1, 2017, corporations will be subject to a higher corporate income tax rate. The tax reform reduces some tax rates for individuals, including nonresident individuals. 05 January 2017

Uruguay

Topic

Description

Date

Uruguay's Executive Power issues Decree regulating requirements for entities to inform Central Bank of their ultimate beneficial owners and nominative shareholders New regulations implement requirements created by a 2016 fiscal transparency law for certain entities to report their ultimate beneficial owners and nominative shareholders. 01 August 2017
Uruguay's Executive Power formally proposes accountability bill Taxpayers should follow the progress of this bill, which proposes some significant tax increases. 28 June 2017
Uruguay modifies tax treatment of transactions with derivative financial instruments The Decree includes new tax rules for derivative financial instruments that reduce the tax liability for taxpayers in some cases. 30 May 2017
Uruguay establishes payment regime for tax liabilities resulting from notional dividends Uruguay’s Economy and Finance Ministry has issued a decree that establishes a payment regime for tax liabilities resulting from notional dividends. 03 May 2017
Uruguay issues guidance on fiscal transparency law Uruguay's President and Council of Ministers issued guidance which aligns Uruguay's fiscal transparency rules with international standards on international fiscal transparency matters. 04 April 2017
Tax treaty between Uruguay and Singapore enters into force On March 14, 2017, the Double Taxation Avoidance Treaty between Uruguay and Singapore entered into force. 17 March 2017
Uruguay issues list of low or no taxation jurisdictions Uruguayan tax authorities have issued a resolution listing the countries or jurisdictions that qualify as low or no taxation. 16 March 2017

Uruguay's Parliament approves bill regarding income tax on derivative financial instruments

Uruguay's Parliament has approved a bill that would regulate the taxation of transactions involving derivative financial instruments.

06 January 2017

Uruguay extends VAT rate reduction

On December 26, 2016, Uruguay's Economy and Finance Ministry issued a Decree, extending the VAT rate reduction established by Law No. 19,210 and regulated by Decree 203/2014 (July 22, 2014).

05 January 2017

×

Back to the Center for Tax Policy

Connect with us

Stay connected with us through social media, email alerts or webcasts. Or download our EY Insights app for mobile devices.