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Latin America in Focus
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.
Brazil
New NR issued on MAP rules for resolving treaty disputes
Brazil’s tax authorities published a normative ruling on 10 November 2016, which provides guidance on the mutual agreement procedure in the context of Brazil’s 32 tax treaties, and to implement the OECD recommendations under action 14 of the BEPS project (“Making Dispute Resolution Mechanisms More Effective”).
Public consultation announced on CbC reporting
Brazil’s tax authorities and the Ministry of Finance jointly released a public consultation document on 7 November 2016 that contains measures to implement the OECD recommendations under action 13 (country-by-country reporting) of the BEPS project.
Mutual assistance convention in force in Brazil
The multilateral Convention on Mutual Administrative Assistance in Tax Matters (as amended by the 2010 protocol) entered into force in respect of Brazil on 1 October 2016 and generally will apply as from 1 January 2017.
Ruling issued on WHT treatment of technical service/assistance fees
Brazil’s tax authorities issued a ruling on 9 November 2016 concluding that payments made from a Brazilian source to an individual or a legal entity resident in Finland for the provision of technical services or technical assistance is not subject to withholding tax in Brazil under the tax treaty with Finland.

Colombia
Tax treaty signed with UK
On 1 November 2016, Colombia and the UK signed the first tax treaty between the two countries.
Tax reform bill presented to Congress
Colombia’s Ministry of Finance presented a tax reform bill to Congress on 19 October 2016, which contains extensive proposed changes that would affect companies, individuals and nonprofit entities, as well as VAT and other indirect taxes and tax administration.

Costa Rica
Income tax rates for FY 2017
Executive Decrees published in Costa Rica's official newspaper on 29 September 2016 set out the new personal income tax brackets for salary income fiscal year 2017.

Mexico
Congress approves 2017 tax package
The Mexican Senate approved the 2017 tax package on 26 October 2016, and the package has been sent to the president for enactment and publication in the official gazette.

Panama
New accounting record obligations imposed on offshore legal entities
A new law introduced in Panama on 27 October 2016 includes an obligation for certain entities to maintain accounting records and supporting documentation.
Updated rules issued on arm’s length principle and transfer pricing documentation
An Executive Order published in Panama’s official gazette on 25 October 2016 amends the provisions of the tax code relating to the arm's length principle to bring the rules in line with the internationally agreed standards generally reflected in tax treaties.

Helpful resources
These materials are available to further support your cross-border efforts:
Access previous editions of the newsletter
Latin America in Focus - May 2016
Latin America in Focus - February 2016
Latin America in Focus - December 2015
Latin America in Focus - October 2015
Contact us
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.