Latin America in Focus — December 2015
Staying ahead of cross-border operations
Latin America's emergence as a world market has been, and continues to be, accompanied by an upsurge in the complexity of laws, regulations, and practices impacting cross-border operations throughout the region. Latin America in Focus shares the latest developments with consequences for the region's tax, legal, and overall business environment—developments that businesses and individuals with investments in Latin America cannot afford to ignore.
Click on any of the headings below to read more about the topic.
Becoming a Multilatina – key factors to regionalizing in Latin America
This report takes an in-depth look at the key differences between Multilatinas and Global Latina companies, and how those differences affect a company's strategy, capabilities and performance. It also identifies country-specific factors that affect business growth—specifically, economic situation, political stability, and access to capital—while offering detailed and actionable insights that senior executives and national policymakers can use to help their companies operate effectively within Latin America and succeed as Multilatinas.
Court rules on INE treatment
Brazil’s Superior Court of Justice (STJ) has ruled that interest on net equity (INE) distributed between two Brazilian entities must be computed for the purposes of the PIS and COFINS taxes (social security contributions on revenue) as financial income at the level of the recipient.
New tax base on software
The São Paulo state tax authorities enacted a decree on 29 September 2015 that revises the taxable base of the state VAT (ICMS) charged on software transactions.
Guidance issued on attribution of profits to permanent establishments
The tax authorities have published guidance that addresses the application of the rules for the attribution of profits to a permanent establishment.
Changes made to audited financial statement requirement
The Costa Rica tax authorities issued guidance on 14 October 2015 that modifies the rule requiring taxpayers classified as large taxpayers or large territorial enterprises to file audited financial statements within six months of the end of the fiscal period.
CbC reporting and OECD standard for exchange of information introduced
The tax rules have been amended to implement the OECD BEPS initiative on country-by-country reporting and the OECD standard for the automatic exchange of information.
Guidance issued on private binding ruling regime
Peru’s executive branch published a decree on 12 September 2015 that sets out the conditions for taxpayers to request a private binding ruling under the new regime introduced by a 2014 law (Law 30296).
These materials are available to further support your cross-border efforts:
- Global Economic Outlook – 4th Quarter 2015
- 2015 Latin America M&A Guide
- BEPS: Base Erosion and Profit Shifting
- Deloitte CbC Digital Exchange (CDX)
- CFO Insights: Six steps to transforming tax
- Deloitte International Tax Source
- Country highlights
- Deloitte tax@hand
- Deloitte Legal in Latin America
- Deloitte 2015 Global Report
For more information, please contact the Americas Tax & Legal Hub.
Note: Latin America in Focus is not intended to be an inclusive update for all Latin America countries but rather features key developments for applicable countries as available.