Latin America in Focus

Barbados

IBC and ISRL regimes to be abolished and no new licenses to be granted

The prime minister has reaffirmed the government’s commitment to removing preferential tax regimes that cause ring-fencing of the international business sector and, as from 1 January 2019, international business companies and international societies with restricted liability will become regular Barbados companies.

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Brazil

Exchange of CbC reports initiated

The tax authorities have initiated the exchange of country-by-country reports with other jurisdictions.

Access to mutual agreement procedure expanded

New guidance extends access to the MAP to taxpayers whose disputes have been subject to a court decision.

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Chile

MFN clause applies in Chile’s tax treaties with Austria, China, Ecuador and Spain

The tax authorities have issued guidance on the MFN clauses in four tax treaties following agreement to the revised wording for the relevant articles from the relevant treaty partner tax administrations.

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Colombia

Guidance issued on procedure for filing CbC report

The Colombian tax authorities have published guidance for taxpayers to submit a country-by-country report for fiscal year 2017, as well as the information to be included in the report.

2019 finance bill proposes significant tax reforms

The finance bill includes a gradual reduction in the corporate income tax rate and a reduction in the VAT rate.

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Costa Rica

New law makes broad changes to corporate tax rules, introduces VAT

In addition to the introduction of a VAT regime, the law includes a 15% capital gains tax and a 15% tax on movable capital and a tax amnesty.

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Ecuador

Certain financial reporting obligations abolished

Certain forms are no longer necessary because the information can be obtained from other sources.

El Salvador

Companies receive Authorized Economic Operator status

Two companies have been certified under the Authorized Economic Operator Program.

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Guatemala

Crediting of income tax and solidarity tax payments

Companies that are taxed under the general tax regime and that are approaching their fiscal year-end should review their tax credit options.

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Mexico

Proposal announced for law to promote public trust

A member of Morena’s parliamentary group has proposed the introduction of a law that would grant tax and administrative benefits/incentives with fewer formalities. 

More tax reform proposals released

The congress has presented several more proposed changes to the tax code, income tax, VAT and excise tax laws.

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Panama

Multinational headquarters regime amended in line with BEPS action 5

Tax and non-tax changes have been made to the multinational headquarters regime, including the introduction of a 5% tax on incentivized activities that previously were tax-exempt. The tax changes will bring the regime in line with the recommendations under action 5 of the OECD/G20 BEPS project.

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Peru

Due date extended for filing CbC report for FY 2017

Peruvian subsidiaries of foreign multinational entity groups have until March 2019 to file the CbC report if the multinational’s parent company is required to file a CbC report in its country of residence.

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