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Tax Policy Dispatch

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

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Canada


Topic Description Date
Canada’s Finance Minister tables NWMM for tax measures and adjusts proposed filing deadline for Form T1134s Federal Finance Minister Bill Morneau tabled a notice of ways and means motion (NWMM) on October 25, that includes most of the draft legislative proposals released on July 27. 29 October 2018
Canada’s Department of Finance announces new global steel safeguard surtax; implements remission order for surtaxes on certain US origin goods The Department of Finance announced a new 25% global safeguard surtax on steel products, subject to a Canadian International Trade Tribunal injury inquiry. 16 October 2018
Canada's Department of Finance releases draft legislation for 2018 budget and other measures for comment The Department of Finance released for consultation a package of draft legislative proposals and explanatory notes relating to a number of measures announced in the 2018 federal budget. 31 July 2018
Duty relief, duty drawback, and remission available for Canadian surtaxes on certain US originating goods Importers can take advantage of the Duties Relief Program and/or Duty Drawback Program to defer or obtain a refund of the recent surtax imposed under the United States Surtax Order (Steel and Aluminum) (SOR/2018-152) and the United States Surtax Order (Other Goods) (SOR/2018-153) for imported goods that are re–exported or are used as inputs or consumed in producing other goods for export. 20 July 2018
Canada updates final import surtaxes imposed on certain products originating in the United States Effective July 1, Canada imposed a 25% or 10% surtax on steel and aluminum products and many consumer goods originating in the United States under two retaliatory surtax orders. 09 July 2018
Canada to impose retaliatory tariffs on certain US origin products starting July 1 Canada has proposed retaliatory measures against CDN$16.6 billion worth of US imports of steel, aluminum and many finished goods. 13 June 2018
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United States


Topic Description Date
IRS adds five new LB&I compliance campaigns, bringing total number to 50 The IRS has selected five new Large Business and International (LB&I) compliance campaigns, bringing to 50 the total number of LB&I compliance campaigns announced since passage of the Tax Cuts and Jobs Act. 05 November 2018
Japan and US sign Country-by-Country Reporting exchange of information arrangement The competent authorities of Japan and the United States signed, on 12 October 2018, an arrangement for the exchange of Country-by-Country Reporting. The arrangement entered into effect on the same date. 01 November 2018
More states respond to Wayfair, set sales tax collection dates for remote retailers A number of states have issued guidance on the impact of this historic ruling on their sales and use tax laws, including application of existing economic nexus standards. 23 October 2018
IRS guidance addresses many, though not all, questions about Opportunity Zones The IRS released proposed regulations (REG-115420-18) and a revenue ruling (Revenue Ruling 2018-29) providing guidance on Section 1400Z-1 qualified opportunity zones (Opportunity Zones) and the related Section 1400Z-2 tax treatment. 23 October 2018
Federal proposed Section 951A GILTI regulations have state tax implications Because nearly every state with a corporate or personal income tax relies upon the IRC in some manner, the regulations will have important implications for reporting purposes for US state and local, personal, corporate and other business taxes. 22 October 2018
EY QUEST report compares macroeconomic impacts of carbon regulations to a carbon tax The report compares the macroeconomic impacts of carbon regulations to a carbon tax that achieves the same reduction in carbon emissions. 19 October 2018
OIRA Fall Agenda sets targets for release of TCJA regulations OIRA’s fall agenda reflects plans for the imminent release of regulations implementing a variety of aspects of the Tax Cuts and Jobs Act. 17 October 2018
IRS announces intent to issue proposed regulations on the deductibility of expenses for certain business meals In Notice 2018-76 the Treasury Department and the Internal Revenue Service announced their intent to issue proposed regulations on the deductibility of expenses for certain business meals. 09 October 2018
Maryland issues guidance on reporting and taxing IRC Section 965 income for tax year 2017 The Comptroller of Maryland issued a tax alert to provide guidance on reporting and taxation of IRC Section 965 repatriation income for tax year 2017. 16 October 2018
Opportunity Zone regulations may come in two rounds, Treasury official announces A Treasury official has announced that the pending proposed regulations on Opportunity Zones could be supplemented by additional regulations later this year. 05 October 2018
IRS announces changes to Section 965 transition tax rules affecting basis election deadline, aggregate foreign cash position, and relief in connection with Hurricane Florence In Notice 2018-78, the US Treasury Department and the Internal Revenue Service (IRS) have announced certain amendments to the rules included in the proposed regulations under Section 965 02 October 2018
Tax reform permanency bill passed in 2.0 effort None of the bills are expected to be taken up in the Senate prior to the midterm elections. Retirement provisions are seen as having the best chance of being enacted during the post-election lame-duck session. 29 September 2018
Treasury and IRS propose removing Section 385 documentation requirements The proposed regulations would remove the minimum documentation requirements that must be satisfied to treat certain financial arrangements among related parties as indebtedness for federal tax purposes. 24 September 2018
Proposed GILTI regulations provide useful guidance on certain consolidated return issues Describes consolidated return aspects of the regulations. 17 September 2018
Proposed GILTI regulations implement international tax reform changes The US Treasury Department and Internal Revenue Service issued highly anticipated proposed regulations under the global intangible low-taxed income regime. 16 September 2018
Tax Reform 2.0 bills approved by Ways & Means The House Ways and Means Committee has approved the three-bill Tax Reform 2.0 package. 14 September 2018
IRS announces five new LB&I campaigns The IRS Large Business and International Division (LB&I) identified five new campaigns that expand the focus areas under its issue-based examination program. 14 September 2018
OECD releases additional guidance on Country-by-Country Reporting and updated exchange relationships The guidance on provides greater certainty to tax administrations and multinational enterprise groups on the implementation and operation of Base Erosion and Profit Shifting Action 13 Country-by-Country Reporting. 14 September 2018
Tax Reform 2.0 bills released House Ways and Means Committee Chairman Kevin Brady (R-TX) released the legislative text of the three bills that comprise the Tax Reform 2.0 package to: (1) make permanent individual and small business tax cuts under the Tax Cuts and Jobs Act that expire at the end of 2025; (2) promote savings for families and retirement; and (3) promote innovation. 11 September 2018
QUEST Trade Policy Brief highlights economic implications of key US and global trade issues — September 11, 2018 This edition discusses the proposed 25% US tariff on automobile imports, the possible economic effects of a 25% retaliatory tariff imposed on US automobile exports by US trading partners, and the potential adverse effects of these tariffs on the US automobile industry and consumers. 11 September 2018
Payments under state and local tax credit programs remain deductible as business expenses, IRS clarifies The FAQ clarifies that recently issued proposed regulations do not affect business taxpayers' ability to claim business expense deductions for certain payments to charities or government entities for which taxpayers receive state and local tax credits. 10 September 2018
IRS announces changes to Compliance Assurance Program The changes are intended to continue and improve operation of the program in light of the IRS's limited resources. 05 September 2018
US issues new steel and aluminum proclamations outlining potential relief opportunities for US importers US President Trump signed two Presidential proclamations on August 29, granting targeted relief to US importers of steel and aluminum products that are subject to country specific quotas covered by Section 232 of the Trade Expansion Act of 1962. 04 September 2018
US and Mexico reach agreement on trade relations; NAFTA fate uncertain On August 27, after more than a year and seven NAFTA renegotiation rounds, Mexico and the US announced a "preliminary agreement in principle." 29 August 2018
Proposed regulations would affect all state and local tax credit programs, not just those recently enacted in response to the federal $10,000 SALT deduction cap The Treasury and IRS have published much-anticipated proposed regulations (REG-112176-18) on the deductibility for federal income tax purposes of charitable contributions for which a taxpayer received a state or local tax (SALT) benefit. 29 August 2018
IRS issues guidance on Section 162(m), as amended by the 2017 Tax Act The Internal Revenue Service has provided guidance on the changes made to Section 162(m) under the TCJA. 23 August 2018
IRS issues guidance for complying with favorable small-business taxpayer rules under the Tax Cuts and Jobs Act The IRS has outlined the process through which eligible small-business taxpayers — generally those with average gross receipts of $25 million or less in the prior three years — may obtain automatic consent to change certain methods of accounting. 21 August 2018
Proposed regulations released on computing TCJA's pass-through deduction Pending the issuance of the final regulations, the Proposed Regulations explicitly state that taxpayers may rely on the proposed Section 199A regulations until final regulations are published in the Federal Register. 15 August 2018
More states respond to the US Supreme Court's ruling in South Dakota v. Wayfair States have issued guidance on the impact of Wayfair on their sales and use tax laws, including application of existing economic nexus standards and when such standards will apply. 13 August 2018
IRS and Treasury issue Section 168(k) proposed regulations on 100% bonus depreciation The IRS and Treasury have released proposed regulations on the allowance for the additional first-year depreciation deduction under Section 168(k), as amended by the Tax Cuts and Jobs Act, for qualified property acquired and placed in service after September 27, 2017. 10 August 2018
Proposed Section 965 regulations provide guidance to private foundations regarding income to be included in net investment income This Tax Alert focuses on the implications of the proposed regulations to private foundations. 10 August 2018
Proposed Section 965 regulations have implications for S corporations, partnerships and individuals Provides an overview of how the proposed regulations affect taxpayers investing through domestic and foreign pass-through entities, including partnerships, S corporations, trusts, and estates, as well as individuals. 09 August 2018
Federal proposed Section 965 transition tax regulations have state tax implications Since nearly every state with a corporate or personal income tax relies upon the IRC in some manner, the Proposed Regulations will have important implications for reporting purposes for US state and local, personal, corporate and other business taxes. 08 August 2018
US Treasury Department releases proposed Section 965 regulations 05 August 2018
States respond to the US Supreme Court ruling in South Dakota v. Wayfair Presents a summary of official state announcements and guidance, as of July 19, 2018. 20 July 2018
Canada updates final import surtaxes imposed on certain products originating in the United States Effective July 1, Canada imposed a 25% or 10% surtax on steel and aluminum products and many consumer goods originating in the United States under two retaliatory surtax orders. 09 July 2018
OECD releases first discussion draft on transfer pricing aspects of financial transactions The Organisation for Economic Co-operation and Development released the first public discussion draft on the transfer pricing aspects of financial transactions on July 3. 09 July 2018
Overnight, New Jersey completely overhauls its Corporation Business Tax Act On July 1, 2018, New Jersey enacted sweeping changes to its Corporation Business Tax Act, resulting in possibly the most significant overhaul of that law since 1945. 02 July 2018
Accounting considerations of the US Supreme Court's elimination of physical presence standard for sales and use tax collections One of the most pressing questions raised by the Court's decision is whether states will now attempt to assert liability for uncollected taxes on a retroactive basis. 28 June 2018
CBO releases Long-Term Budget Outlook The Congressional Budget Office on June 26, 2018, released the 2018 Long-Term Budget Outlook, affirming its previous report that federal debt held by the public will approach 100% of GDP by 2028, and projecting it will then soar to more than 150% of GDP by 2048. 27 June 2018
OECD releases final revised guidance on application of transactional profit split method The Organisation for Economic Co-operation and Development has released the final report on the revised guidance on the application of the transactional profit split method. 27 June 2018
OECD releases guidance for tax administrations on application of approach to hard-to-value intangibles The Organisation for Economic Co-operation and Development released final guidance for tax administrations on the application of the approach to hard-to-value intangibles. 27 June 2018
US Supreme Court overturns Quill, eliminates physical presence nexus standard for sales and use tax collection On June 21, 2018, the US Supreme Court voted to overturn both Quill and National Bellas Hess, finding that the physical presence nexus standard articulated in the two earlier opinions "is unsound and incorrect." 21 June 2018
Additional delay of Section 987 foreign currency regulations has immediate significance for taxpayers, including CFCs The US Treasury Department and the US Internal Revenue Service announced that they intend to amend the final regulations under Section 987 to further delay the applicability date of the regulations by one additional year. 18 June 2018
US imposes first set of tariffs on China origin products; publishes list of $34 billion in goods subject to additional 25% duty effective July 6 The President of the United States announced June 15, that the United States will move forward and implement a 25% tariff on US$34 billion of goods from China that contain industrially significant technologies. 18 June 2018
IRS updates Section 965 transition tax FAQs to include late-payment penalty and filing relief On June 4, 2018, the IRS updated “Questions and Answers about Reporting Related to Section 965 on 2017 Returns” (the FAQs, originally released March 13, 2018). 06 June 2018
IRS announces six new LB&I campaigns The IRS Large Business and International Division (LB&I) has identified six new campaigns that expand the focus areas under its issue-based examination program. 29 May 2018
IRS issues notice on state and local tax deductions Notice 2018-54 states that proposed regulations will be issued addressing the deductibility of state and local tax payments for federal income tax purposes and informing taxpayers that federal law controls the characterization of the payments for federal income tax purposes. 23 May 2018
Tax reform proposed in Puerto Rico Puerto Rico's House of Representatives has proposed to amend the Puerto Rico Internal Revenue Code of 2011 to modify the way individuals and corporations are taxed in Puerto Rico. 17 May 2018
IRS releases new template for APA agreements The Internal Revenue Service has released a revised mandatory template for Advance Pricing Agreements (APAs) to be included in all taxpayer APA requests. 15 May 2018
EY's Tax Guide — your one-stop resource for Tax Cuts and Jobs Act information and planning EY's Tax Guide to the TCJA is a one-stop resource that can make the research process quick and efficient. 14 May 2018
IRS announces forthcoming regulations expanding exception to definition of US property under Section 956 The IRS plans to issue regulations to expand the exception to the definition of United States property under Section 956(c). 09 May 2018
Technical corrections to partnership audit rules included in Appropriations Act The Act addresses a number of procedural and substantive rules under the BBA, including the scope, netting, push-out election, and special enforcement matters. 20 April 2018
IRS updates to FAQs affect transition tax 2017 extension payments and 2018 Q1 estimated payments On April 13, 2018, the IRS updated Questions and Answers about Reporting Related to Section 965 on 2017 Returns (the FAQs, originally released March 13, 2018). 13 April 2018
US issues CbC reporting guidance for specified national security contractors The IRS has set forth modified reporting requirements for Form 8975, Country-by-Country Report, for US multinational enterprise groups that derive more than 50% of their annual revenues from the Department of Defense or other US governmental intelligence or security agencies. 11 April 2018
CBO forecasts higher deficits, debt due to TCJA and spending bills The federal budget deficit will exceed $1 trillion annually beginning in FY 2020 — two years earlier than previously projected — and federal debt held by the public will approach 100% of GDP by 2028, according to the Congressional Budget Office (CBO) Budget and Economic Outlook released on April 9, 2018. 09 April 2018
Notice 2018-26 announces anti-avoidance rules and other regulations on the transition tax provision in Section 965 The IRS and Treasury intend to issue new regulations under Section 965 on determining the amount of gross income recognized by US shareholders as an inclusion of deferred foreign income (transition tax). 08 April 2018
IRS reporting guidance on Section 965 transition tax has state tax implications This Alert focuses on the state corporate income tax implications of the guidance provided in the Section 965 FAQs. 23 March 2018
IRS issues guidance on Section 965 transition tax in form of frequently asked questions The IRS has posted to IRS.gov new guidance under Section 965 in the form of frequently asked questions (FAQs) to help taxpayers meet their reporting, filing and payment requirements under Section 965 (the transition tax) enacted by the Tax Cuts and Jobs Act, P.L. 115-97. 20 March 2018
IRS announces five new LB&I campaigns The IRS Large Business and International Division identified five new campaigns that expand its focus areas under its issue-based examination and compliance process, with a particular emphasis on passthrough entity issues. 16 March 2018
US President Trump imposes tariffs on steel and aluminum products — Mexico and Canada excluded President Trump signed Presidential proclamations on March 8, imposing additional tariffs of 25% on specifically defined articles of steel, and additional tariffs of 10% on specifically defined articles of aluminum, effective on March 23. 09 March 2018
Notice 2018-18 announces that S corporations will be subject to new carried interest holding period rule The IRS announced its intention to issue regulations stating that carried interests held by S corporations will not qualify for the exception from the Tax Cut and Jobs Act's carried interest provision for interests held by corporations. 07 March 2018
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Mexico and Central America


Costa Rica

Topic Description Date
Costa Rica's tax authorities issue resolution on the dates to comply with the general obligation to use electronic vouchers Under the Resolution, taxpayers must begin issuing electronic vouchers in accordance with the last digit of their individual identification number or corporate identification number. 23 March 2018

El Salvador

Topic Description Date
El Salvador recently updated the transfer pricing information return and guidelines Taxpayers should ensure they have the documentation necessary to electronically file the new transfer pricing information return. 22 October 2018
El Salvador's tax authorities publish a revised list of tax havens for 2019 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%. 05 October 2018

Mexico

Topic Description Date
Mexico broadens source taxation on software payments Under the amendments, even the slightest modification could cause payments for the use of software to be treated as royalties. 05 November 2018
Mexico takes retaliatory measures against US imposition of steel and aluminum tariffs On 5 June 2018, the Mexican Government published the list of products that, effective on such date, are subject to a retaliatory duty. 13 June 2018
Philippines-Mexico Income Tax Treaty enters into force The Philippines-Mexico Income Tax Treaty entered into force on April 18, and will become effective on January 1, 2019. 09 May 2018
Mexican Senate approves bill giving tax authorities new powers to challenge application of net operating losses The new bill would allow the Mexican tax authorities to assume that a taxpayer conducted an unlawful transfer of net operating losses to obtain a tax benefit. 25 April 2018
Mexico modifies transfer pricing deadlines for filers of DISIF Taxpayers should be preparing their transfer pricing information now to meet the March 31 filing deadline. 16 February 2018
Mexican Supreme Court rules taxpayers will have to file accounting records for January 2015 and onwards Because of the injunction granted by the Mexican Supreme Court of Justice, taxpayers with cases still pending do not have to electronically file their accounting records. 03 November 2017

Panama

Topic

Description

Date

Multinational headquarters companies are subject to transfer pricing regulations in Panama Entities with a multinational headquarters license are now subject to the transfer pricing regulations and should ensure they comply with those regulations. 06 November 2018
Taxpayers with a concession for call center activities are subject to transfer pricing regulations in Panama Entities with a concession for call center activities are now subject to the transfer pricing regulations and should ensure they comply with those regulations. 29 October 2018
Panama establishes tax amnesty Taxpayers who might benefit from the tax amnesty should review the requirements before December 31, 2018. 03 October 2018
Panama establishes a pilot program for using electronic invoices The Resolution authorizes certain companies with commercial activities that require an electronic billing system to use electronic invoices in Panama. Such companies should ensure that they comply with the Resolution and that they follow the implementation procedures set out in the data sheet. 01 October 2018
Panama's Minister for Foreign Affairs proposes bill to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS Panama's Minister for Foreign Affairs proposed Bill No. 6781 to the National Assembly to initiate the process of ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS. 25 September 2018
Panama issues its list of reportable jurisdictions for CRS purposes Panama issued Executive Decree No. 122 of June 11, 2018, which adopts the list of reportable jurisdictions for Common Reporting Standard purposes. 20 June 2018
Panama and Uruguay agree to first exchange of financial account information for 2017 The Panamanian and Uruguayan Government agreed to begin the first exchange of financial account information in tax matters for 2017 on May 7, 2018. 16 May 2018
Uruguay issues Decree establishing conditions for Panama to be removed from list of countries with low or no taxation Panama may no longer be considered a low- or no-taxation country by Uruguay, provided Panama complies with certain conditions. 04 May 2018
Panama publishes new version of transfer pricing information return Taxpayers should ensure that they comply with the filing of the new version of Form 930. 16 April 2018
Panama signs Multilateral Convention to implement tax treaty related measures to prevent BEPS Panama signed the Multilateral Instrument and submitted a list of 17 tax treaties that it would like designated as covered tax agreements. 25 January 2018
European Union removes Panama from list of non-cooperative jurisdictions for tax purposes The European Union has removed Panama from its black list, along with seven other jurisdictions. 24 January 2018
Panama modifies deadlines for FATCA and CRS purposes Panama’s decree amends reporting deadlines for financial institutions and cutoff dates to determine account balances for Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) purposes. 05 January 2018
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Tax policy outside the Americas


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

Japan

Topic

Description

Date

Japan enacts 2018 tax reform bill Japan's 2018 tax reform bill (the Bill) was enacted on March 28, following passage of the Bill by the Japanese Diet. 06 April 2018

Korea

Topic

Description

Date

Korea promulgates Enforcement Decree for 2018 tax reform bill Korea promulgated the revised Enforcement Decree of Korean tax laws to provide more specific guidance on the 2018 tax reform bill which was enacted December 19, 2017. 07 March 2018
Korea enacts 2018 tax reform bill The 2018 Tax Reform also includes provisions in line with the Organisation for Economic Co-operation and Development's Base Erosion and Profit Shifting (BEPS) Action 2 and Action 4, among others. 05 January 2018

Philippines

Topic

Description

Date

Philippines proposes corporate tax reform bill

The bill seeks to reduce the Philippine corporate income tax rate while modernizing investment tax incentives and removing excessive tax exemptions and privileges. 09 April 2018

Poland

Topic

Description

Date

Poland issues an extensive 2019 tax reform package, including new innovation box legislation

Poland’s Ministry of Finance has released a draft bill introducing significant changes to the tax law beginning 2019. 11 September 2018

Sweden

Topic

Description

Date

Sweden enacts major corporate income tax changes The new rules will come into effect January 1, 2019 and will apply for the first time to fiscal years beginning after December 31, 2018. 21 June 2018
Sweden proposes major corporate income tax changes The Swedish Government submitted a draft bill on March 21, regarding important changes in the corporate taxation area to the Council on Legislation for their consideration. The new rules are proposed to come into effect January 1, 2019. 26 March 2018

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

Taiwan

Topic

Description

Date

Taiwan enacts tax reform proposals

Taiwan's Legislative Yuan (Parliament) has enacted the tax reform proposals that were announced on September 1, 2017.

25 January 2018

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South America


Argentina

Topic

Description

Date

Argentina and Brazil Amendment Protocol to Tax Treaty will enter into force Argentina and Brazil have fulfilled their domestic law requirements and made the proper notifications for the Amendment Protocol to the tax treaty, meaning the protocol will enter into force on July 29, 2018. 10 July 2018
Argentina publishes mechanism for paying VAT on digital services and list of foreign providers Argentina published resolution implementing the mechanism for the payment of VAT on digital services provided by foreign entities and used in Argentina. 22 May 2018
Argentina increases the amount of tax on debits and credits in local bank accounts that taxpayers may use to offset income tax Taxpayers may be able to offset more of their income tax with the tax paid on debits and credits in local bank accounts. 14 May 2018
Argentina publishes new regulations on the tax revaluation option and VAT on digital services, enacted as part of tax reform When calculating the value of their assets in Argentina, taxpayers may want to consider the tax revaluation option, enacted as part of tax reform. Taxpayers also should be aware of their VAT obligation for digital services. 05 May 2018
Argentina issues additional regulations on the taxation of non-resident investors Taxpayers doing business in Argentina should review these new regulations and determine the effect of the regulations on their business. 12 April 2018
Key aspects of the Argentine tax reform discussed Taxpayers should review the tax reform provisions and take them into consideration when evaluating their operations. 09 January 2018
Argentina enacts comprehensive tax reform Argentina enacted comprehensive tax reform on December 29, 2017. The law is generally effective January 1, 2018. 29 December 2017

Brazil

Topic

Description

Date

Brazilian tax authorities provide guidelines for classifying a transaction as an export of services The ruling provides welcome guidance for Brazilian service providers. 02 November 2018
Brazilian tax authorities propose rules for corporate taxpayer classification The proposed ordinance would impose a new classification system on corporate taxpayers to allow the tax authorities to identify taxpayers that have not complied with tax filing and payment obligations. 26 October 2018
Rio de Janeiro Government in Brazil establishes tax amnesty program Taxpayers who might qualify for the tax amnesty program should monitor the release of the regulations. 17 October 2018
Presidential election will significantly affect Brazil's tax policy After a tumultuous year in Brazilian politics, two presidential candidates have emerged from the first phase of a two-part election process. 09 October 2018
Argentina and Brazil Amendment Protocol to Tax Treaty will enter into force Argentina and Brazil have fulfilled their domestic law requirements and made the proper notifications for the Amendment Protocol to the tax treaty, meaning the protocol will enter into force on July 29, 2018. 10 July 2018
Brazil and Switzerland sign a double tax treaty Brazil and Switzerland have signed a treaty for the elimination of double taxation with respect to taxes on income and the prevention of tax evasion and avoidance. 14 May 2018

Colombia

Topic

Description

Date

Tax reform proposed in Colombia The bill mixes elements of a business-friendly reform with rules that would generate greater revenues for Colombia in the short term. 06 November 2018
Colombia's Ministry of Finance provides more details on upcoming tax reform It is possible that the proposed tax reform could reduce corporate income tax rates and increase individual income tax rates. The VAT rate also may be reduced. 29 October 2018
Colombia issues final regulations on VAT obligations of foreign service providers The resolution imposes new reporting and filing requirements on foreign service providers. As a result, foreign service providers may be required to collect VAT on services rendered to Colombian residents. 25 October 2018
Colombia's tax authority issues a draft resolution on the collection of VAT on electronic digital services provided from abroad Once issued as final, the resolution will establish a new VAT collection mechanism for electronic digital services provided by foreign service providers. 17 October 2018
Tax reform bill submitted to Colombia's Congress The recently proposed tax reform bill would reduce the corporate income tax rate and would no longer limit carryforwards of net operating losses. Taxpayers should follow the progress of this tax reform bill, as well as other tax reform bills that might be proposed, as tax reform is expected to be enacted by the end of 2018. 20 August 2018
Colombia requires certain foreign service providers to register with Colombian tax registry for VAT purposes The decree requires foreign service providers to register in the Colombian tax registry when providing services to Colombian recipients who are not required to collect value added tax via the "reverse charge mechanism." 17 August 2018
Colombia signs tax treaty with Italy The Government of Colombia and Italy signed a Treaty to Avoid Double Taxation that includes new regulations that are intended to reduce the tax burden on transactions that take place between these jurisdictions. 23 March 2018
Colombia issues regulations on obligation to notify tax authorities about country-by-country report Taxpayers should review the new decree to determine whether they must file a CbC report.

09 January 2018

Ecuador

Topic

Description

Date

Ecuador enacts new law that includes tax amnesty and new tax incentives The law includes many new benefits for taxpayers, including tax amnesty and reduced corporate income tax rates. 30 August 2018
Ecuador enacts new law on deductibility of interest derived from 'back-to-back' credit transactions Under the new law, taxpayers may deduct interest derived from "back-to-back" credit transactions. Under an Administrative Resolution, however, taxpayers will no longer be able to deduct expenses related to "back-to-back" loans. 16 July 2018
Ecuador amends its tax law The new law includes many tax rate changes, including an increase to the corporate income tax rate. 26 January 2018
Ecuador approves a new Convention to Avoid Double Taxation with Russia Taxpayers should review the Convention's provisions, as they may qualify for benefits that were previously not available. 25 January 2018

Peru

Topic

Description

Date

Peru amends income tax law to add new thin capitalization rules and indirect foreign tax credit

The income tax law changes broaden the application of the interest deduction limitation to unrelated parties and allow interest that is not deducted to be carried forward for four years.

17 September 2018

Peru enacts provisions with regard to the General Anti-Avoidance Rule

Once regulations are issued, Peru's GAAR will apply from July 19, 2012 and thereafter.

17 September 2018

Peru amends transfer pricing rules

The Legislative Decree broadens the application of the transfer pricing rules to include transactions with residents in "non-cooperating jurisdictions" and residents whose revenue or income is subject to a "preferential tax regime."

05 September 2018

Peru amends income tax law with regard to tax havens and preferential tax regimes

The new legislative decree amends the definitions of tax havens and preferential tax regimes and expands the transfer pricing rules to transactions with entities subject to preferential tax regimes.

04 September 2018

Peru amends income tax law and REIT tax rules and enacts provisions with regard to ultimate beneficial ownership of legal entities

The new decrees establish new rules for royalties and service payments to nonresidents, modify the rules applicable to real estate investment trusts and require entities to report ultimate beneficial owners.

07 August 2018

Peruvian Congress grants President power to legislate in tax matters

Taxpayers should continue to monitor the release of any tax guidance in the coming months.

19 July 2018

Peru amends Income Tax Law regulations on tax havens

On January 17, 2018, the Peruvian Government published Supreme Decree 007-2018-EF, amending the Income Tax Law regulations on tax havens.

19 January 2018

Uruguay

Topic

Description

Date

Uruguay's Executive Power issues regulations on the taxation of foreign entities' income from services rendered by electronic means The Decree offers much needed guidance on the taxation of foreign entities' income and the provision of digital services. 14 September 2018
Uruguay's Parliament approves bill establishing new benefits for taxpayers and amending the CIT regime Uruguay's Parliament has approved a bill that would establish new benefits for taxpayers, as well as change the way biotechnology, bioinformatics and software companies calculate the corporate income tax. 25 July 2018
Panama and Uruguay agree to first exchange of financial account information for 2017 The Panamanian and Uruguayan Government agreed to begin the first exchange of financial account information in tax matters for 2017 on May 7, 2018. 16 May 2018
Uruguay issues Decree establishing conditions for Panama to be removed from list of countries with low or no taxation Panama may no longer be considered a low- or no-taxation country by Uruguay, provided Panama complies with certain conditions. 04 May 2018
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Chile

Topic

Description

Date

Chile proposes tax reform The bill is pro-business because of the audit rules and principles that would limit IRS powers and discretionary powers. 28 August 2018
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