Archives: Tax

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Brazil releases manual on Mutual Agreement Procedures

By Alex Jorge, Renato Lopes da Rocha, Randall Fox and James Dalley Brazil has entered into 33 bilateral tax treaties, namely those with Argentina, Austria, Belgium, Canada, Chile, China, Czech Republic, Denmark, Ecuador, Finland, France, Hungary, India, Israel, Italy, Japan, Luxembourg, Mexico, Norway, the Netherlands, Peru, Philippines, Portugal, Russia, Slovakia, South Africa, South Korea, Spain, … Continue Reading

Panama has been removed from the European Union’s list of non-cooperative tax haven jurisdictions

This is a guest post from Fabrega Molino in Panama. Panama has been removed from the European Union’s blacklist – its list of non-cooperative tax haven jurisdictions. The decision was made in Brussels by the EU’s finance ministers, who concluded that Panama has established regulations and filled requirements to address matters of fiscal transparency. The … Continue Reading

Argentina: new double taxation treaties in force with United Arab Emirates and Mexico

By Augusto Mancinelli The double tax treaty between Argentina and the United Arab Emirates is now in force, joining the recently signed DTT between Argentina and Mexico. New DTT: Argentina – United Arab Emirates The Argentina – UAE DTT is applicable to the income tax, presumed minimum income tax and personal assets tax collected by … Continue Reading

Changes to reporting requirements for severance payments in Puerto Rico

By: Mariana Muniz and Juan Carlos Feliciano   For tax year 2018, employers in Puerto Rico will be required to report certain severance payments, as discussed further below, as “exempt wages” on Withholding Statement Form 499R-2/W-2PR (the Puerto Rico equivalent of the US W-2 Form – PR Form W-2),1 as opposed to Form 480.6D. Under Section … Continue Reading

Brazil clarifies how reinsurance companies are taxed

By: Alex Jorge, Leonardo Rzezinski, Rosana Gonzaga Jayme, Humberto Lucas Marini, Renato Lopes da Rocha and Marcella Hill The Brazilian Tax Revenue has published Private Letter Ruling No. 91/2018, as a response by the General Coordination of Taxation (COSIT), which revokes Private Letter Ruling No. 62/2017. The Response to Consultation No. 91/2018, issued in August, … Continue Reading

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
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