Archives: Tax

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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

Latin American countries focus on new legislation around tax and transfer pricing – independence limitations in Ecuador

A recent report published by the United Nations’ Economic Commission for Latin America and the Caribbean (CEPAL) calculated that Latin American countries have lost more than US$98 billion in tax revenues simply  due to transfer pricing manipulation. Latin American countries are paying close attention to such reports, leading to changes in their local regulations or … Continue Reading

Puerto Rico’s Act 20 and Act 22 – Key Tax Benefits

In the midst of a complicated fiscal situation, Puerto Rico continues to attract investors and companies through two extant tax incentive packages: Puerto Rico’s Act 20 – the Promotion of Export Services Act – and Act 22 – the Act to Promote the Relocation of Individual Investors to Puerto Rico. Act 20 and Act 22 were enacted in … Continue Reading
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