Latin America in Focus — December 2015

Featured 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.

Brazil

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.

Colombia

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.

Costa Rica

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.

Mexico

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.

Peru

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).