Archives: Tax

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Argentina introduces VAT on digital services

By: Augusto Nicolás Mancinelli Argentina’s new Law 27,430 introduces a new taxable event: a Value Added Tax (hereinafter VAT) applicable to the importation of “digital services” rendered by a non-resident to a resident individual or entity when the effective use or exploitation of the service is carried out inside Argentina. An earlier regulation, Decree 354/2018 … Continue Reading

Argentina: new export duties in force; peso devaluation may impact inflation

By: Augusto Nicolás Mancinelli The Argentine executive branch has established new export duties applicable to goods and services. These new export duties were established by a Decree of the Executive Power (Decree No. 793/2018) issued on September 3, 2018 and published at the official Gazette on September 4, 2018, with immediate effect for the export … Continue Reading

E-commerce companies: Tax recent developments in Uruguay

Guest post from our friends at Bergstein Abogados Uruguay requires online companies incorporated abroad, with no presence in Uruguay, to pay taxes in Uruguay whenever their clients are located within Uruguayan territory. Online services providers (such as Netflix and Spotify) are subject to VAT at the rate of 22 percent, plus Non-Residents Income Tax (so-called … Continue Reading

Administrative proceeding in State of Rio de Janeiro will allow the compliance of tax discrepancies

The State of Rio de Janeiro enacted the Resolution n° 265 on June 19, 2018, in order to allow taxpayers to regularize their tax debts before starting an official tax audit and to reduce the amount of credits in dispute before the administrative court. The proceeding is called a “friendly warning” and encompasses tax debts … Continue Reading

Brazil introduces US-Brazil Agreement on Social Security

The Brazilian Government has enacted Decree No. 9,422/2018, which introduced into Brazilian law the Agreement on Social Security between the United States and the Federative Republic of Brazil, originally signed on June 30, 2015.  The Agreement was enacted in late June 2018; its enforceability shall commence on October 1, 2018 and shall be applicable to … Continue Reading

Brazil and Switzerland sign DTT, reflecting Brazil’s effort to expand its network of tax agreements

By: Renato Lopes da Rocha Following the execution of an agreement with Switzerland, on May 7, 2018 by virtue of the visit from the Brazilian Minister Aloysio Nunes to Singapore, the Brazilian and Singaporean governments signed the Agreement for Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion … Continue Reading

Brazil and Switzerland sign Convention for Elimination of Double Taxation – highlights

The Governments of Brazil and Switzerland have signed the Convention for Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (DTT). In line with Brazil’s commitments under the G20, the DTT, signed on May 3, 2018, incorporates certain minimum standards of the Organization for Economic Cooperation … Continue Reading

TAX ALERT – INFORMATION ABOUT TAX BENEFITS – SEFAZ/RJ

Rio de Janeiro State Resolution n° 231, from March 23, 2018, establishes certain obligations for taxpayers who enjoy tax benefits for the provision of data to the National Tax Transparency website (CONFAZ), in which shall be publicized all the information and legislation regarding tax benefits. The deadline to present all the data required is April … Continue Reading

Private equity and hedge funds in Puerto Rico – a welcoming environment in the Caribbean

Written by: Nikos Buxeda, Manuel López-Zambrana, Camille Alvarez and Juan Carlos Feliciano Ten years ago, private equity funds and hedge funds were practically nonexistent in Puerto Rico. This has changed dramatically as the result of two main developments: the enactment of Act 185-2014, known as the Private Equity Funds Act and (ii) the influx of … Continue Reading

Tax advantages of Uruguayan holding companies

The following is a guest post by Guzman Ramírez  from Bergstein Abogados, an independent law firm in Uruguay. Uruguay offers a number of tax advantages to multinationals. This has become especially so in the wake of the substantial tax reforms which have taken place in Uruguay in the last few years, under which Uruguay has been … Continue Reading

Convention for the Avoidance of Double Taxation between Brazil and Russia || Convenção para Evitar a Dupla Tributação entre Brasil e Rússia

On August 1st, 2017, it was published the Executive Decree no. 9,115/2017, which internalized the Convention for the Avoidance of Double Taxation between Brazil and Russia (“Brazil-Russia Treaty” or “Convention”), signed in Brasilia on November 22nd, 2004. We have focused on the most relevant points, considering most usual queries of taxpayers. According to article 2 … Continue Reading

Uruguay: Preferential Tax Scheme for International Trading Companies

Guest post by Guzmán Ramirez and Jonás Bergstein, from Bergstein Abogados, an independent law firm in Uruguay. Uruguay is positioning itself as a jurisdiction for multinationals considering an alternative legal platform to conduct operations abroad. The tradition of stability and democracy which characterizes the country, and Uruguay’s achievement of all relevant OECD standards − Uruguay … Continue Reading

Tax incentives in Puerto Rico: a quick introduction: Handbook

To promote, attract and develop key industries, sectors and activities, Puerto Rico offers a spectrum of economic incentives, among them low fixed income tax rates, partial and/or total tax exemptions, income tax credits and special deductions. The manufacturing, tourism, construction, telecoms, export services, renewable energy, film, banking and financial services industries are among the sectors … Continue Reading

Taxation and Reinsurance in Brazil: Regulatory Update

COSIT CONSULTATION RESPONSE 62/2017 The following are comments to the effects of COSIT Consultation Response No. 62, published on 20 January 2017, which the General Office to Coordinate Taxation (“COSIT”) of the Brazilian Federal Revenue Service (“RFB”) expressed its position on the tax regime applicable to reinsurance companies operating in Brazil. Portuguese language is below.… Continue Reading

New transfer pricing requirements in Latin America under BEPS

This publication first appeared as a Latin America Alert on www.dlapiper.com. Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative. In this new year, Mexico, Colombia and Peru have included in their local legislation new documentation requirements that follow a three-tiered … Continue Reading

Uruguay Fully Aligns with OECD Standards: Tax Transparency Law Enacted

The following is a guest post from Bergstein Abogados, Montevideo, Uruguay Over the last few years, Uruguay has fully aligned with OECD standards. For example, Uruguay has entered into more than 10 tax information exchange agreements and more than 15 double taxation agreements. Uruguay became a member of the Committee on Fiscal Affairs, signed the Convention … Continue Reading

US House Tax Bill Proposal – LatAm M&A Implications

This article first appeared as a Financial Services Regulatory Alert on www.dlapiper.com. At the risk of oversimplification, the purchase price on an asset purchase agreement allocable to certain intangibles or goodwill is generally amortized over 15 years.  The House tax bill proposes to allow the full purchase price (allocable to intangibles/goodwill) to be recovered immediately. … Continue Reading

House passes pro-growth bill, HR 6427, 391 – 2: top points

HR 6427, a potentially important piece of financial services related legislation, has been passed by the US House of Representatives by a vote of 391-2. Entitled “The Creating Financial Prosperity for Businesses and Investors Act,” the bill aggregates six House Financial Services Committee measures that each previously passed the House with bipartisan support. The bill … Continue Reading

Public Consultation RFB No. 011/2016 – BEPS’ Country-by-Country Report

By Alex Jorge, tax partner, and Marcelo Siqueira, senior tax associate, of Campos Mello Advogados in Brazil (in cooperation with DLA Piper) On November 7, 2016, the Brazilian Federal Revenue (“RFB”) released the draft of a proposed Normative Rule (Public Consultation RFB No. 11/2016 – click here) regulating the implementation of Country-by-Country Report (“CbC Report”) … Continue Reading

Uruguay’s Territorial Tax System and Residency Rules − Planning Opportunities in the Era of Tax Amnesties

Guest Post: Jonás Bergstein and Guzmán Ramírez are partners in Bergstein Abogados, based in Montevideo, Uruguay Recent voluntary-disclosure programs in Latin America (most notably in Argentina, Brazil, Chile, and Colombia) have cast light on Uruguay as a suitable jurisdiction for Latin America business persons seeking to establish tax residence. Uruguay’s historical political stability, democratic traditions, … Continue Reading

Mexican Government Proposes Tax Incentives on IT Services and R&D Activities for 2017

As part of the 2017 economic budget and proposed tax reform, the Mexican government intends to incentivize a couple of activities that may be intertwined: first, by allowing information technology (IT) services to qualify as an export subject to 0 percent value added tax (VAT), as opposed to the 16 percent general VAT rate; and … Continue Reading
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