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.

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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.

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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.

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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.

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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.

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Other Topics of Interest

Latin America Common Reporting Standard (CRS) updates