A weekly summary of the top weekly tax news, trends
and developments in the Americas

     This week's tax news from the Americas

• Canada | Finance releases details on CA$10m capital gains exemption on sale to employee ownership trust
  In early May 2024, Bill C-69, Budget Implementation Act, 2024, No. 1, received first reading in the House of Commons. Bill C-69 implements the measures contained in the notice of ways and means motion that was tabled on 30 April 2024, including the temporary exemption from taxation of the first CA$10m in capital gains realized on the sale of a business to an employee ownership trust. This measure was first announced in the 2023 fall economic statement and confirmed in the 2024 federal budget.

• Colombian Tax Authority issues new ruling on Significant Economic Presence
  The Colombian Tax Authority issued Ruling No. 100208192-305, aimed at resolving several concerns in relation to the significant economic presence (SEP) rules. Under the SEP rules, nonresidents who sell goods and/or provide certain digital services to customers and/or users located in Colombia may create an SEP. In such a scenario, the nonresident seller will be subject to Colombian income tax either through (i) a 10% withholding tax, or (ii) a 3% income tax calculated on the gross income obtained in Colombia.

• Honduran Tax Authority launches its new Virtual Office
  The Honduran Tax Authority has announced the launch of its new virtual office. The new virtual office aims to streamline and improve the taxpayer experience by providing an online website that simplifies the process and reduces the time required to fulfill tax obligations.

• Peru and United Kingdom conclude negotiations on double tax treaty
  According to a Press Release published by the Communications Office of the Peruvian Ministry of Economy and Finance on 17 May 2024, Peru and the United Kingdom have completed the negotiations of their double tax treaty.

• USTR publishes further guidance on impacted China-origin products subject to additional Section 301 tariffs
  On 22 May 2024, the United States Trade Representative (USTR) issued a formal statement concerning recent updates to the Section 301 tariff actions and published a Federal Register Notice (FRN) detailing the conclusion of the statutory four-year review. The statement and FRN provide additional information for companies in consideration of the 14 May 2024 announcement from the White House and the USTR that formalized continued Section 301 of Trade Act of 1974 duties and intention to increase such duties between 2024 and 2026 on certain Chinese products in strategic sectors totaling US$18b.

• Best practices to prepare a US immigration/global mobility program for potential policy and process shifts discussed
  As US federal elections approach this November, it is a good time for companies to take stock of their US immigration and/or global mobility programs, refresh processes where appropriate, improve program efficiencies and operations, and take actions today to best prepare their company and workforce for any potential future changes in the immigration landscape.

     This week's newsletters

• Report on recent US international tax developments - 23 May 2024
  Our weekly report with brief summaries of all the week's US international tax developments and related activity.
• The Latest on BEPS and Beyond | May 2024
  Attached is EY's monthly report with brief summaries of the latest activity in the OECD Base Erosion and Profit Shifting (BEPS) project as well as country specific legislative and administrative activity, including global and regional policy trends related to the global focus on BEPS.

     This week's tax treaty news from the Americas

• Argentina and Hungary: first round of negotiations for revision to the investment protection agreement held
• Argentina and Korea: meeting held to discuss concluding a tax treaty
• Honduras and People’s Republic of China: fifth round of negotiations for a free trade agreement held
• Peru and United Kingdom: tax treaty initialed
• Venezuela and Turkiye: investment protection agreement ratified by Venezuela

     Upcoming EY webcasts

• 4 June: BEPS 2.0: what to explore with the ongoing activity on Pillars One and Two
• 25 June: What Q2 IFRS Quarterly Tax Developments could impact tax accounting
• 25 June: Sustainability Tax: net zero transition and tax function strategy

A calendar of all upcoming EY webcasts is available.

     Recent EY podcasts

• EY Cross-Border Taxation Spotlight | 23 May 2024
• EY Talks Tax: Spotlight on BEPS 2.0: Developments and practical implications for US MNEs
• EY Talks Tax: Tax in a time of transition: Legislative, economic, regulatory and IRS developments

All episodes of the EY Cross-Border Taxation Spotlight and
EY Talks Tax are available through Apple podcasts.

 
     This week's EY Global Tax Alerts

     Americas Tax Alerts

• Report on recent US international tax developments - 23 May 2024
• Canada | Finance releases details on CA$10m capital gains exemption on sale to employee ownership trust
• Colombian Tax Authority issues new ruling on Significant Economic Presence
• Honduran Tax Authority launches its new Virtual Office
• Peru and United Kingdom conclude negotiations on Double Tax Treaty
• USTR publishes further guidance on impacted China-origin products subject to additional Section 301 tariffs

     Other Global Tax Alerts

• Belgium further aligns Pillar Two legislation with OECD's Agreed Administrative Guidance
• Belgium modernizes investment deduction regime and enhances IP regime
• Belgian tax authorities issue specific Pillar Two notification form requiring immediate action
• Kenya proposes tax changes under the Finance Bill, 2024
• Turkiye increases delay interest and legal interest rates
• UAE is boosting trade through Comprehensive Economic Partnership Agreements

     Transfer Pricing Alerts

• Ghana Revenue Authority issues Practice Notes on double tax relief and minimum chargeable income
• Ghana Revenue Authority issues Ghana's Double Taxation Treaty Administrative Manual
• South Africa | Johannesburg Stock Exchange-listed foreign dividend exemption

     Indirect Tax Alerts

• Saudi Arabia joins the international ATA Carnet guarantee system
• Singapore Revenue Authority announces GST InvoiceNow requirement

     Human Capital Alerts

• Best practices to prepare a US immigration/global mobility program for potential policy and process shifts discussed
• Cyprus further amends new laws for acquiring citizenship by naturalization
• Turkiye announces new visa-free policy for Romanian nationals
• UK’s Home Office confirms changes to EU Settlement Scheme

      This week's EY Industry publications

     Oil and Gas

• Energy M&A Quick Takes: How companies are transforming deal structures

      This week's EY Services publications

     People and Workforce

• How Microsoft built a new mobility model for cross-border talent

     Tax

• How the role of financial controller is evolving

     Risk

• EY Global Integrity Report 2024

Additional resources

Comments. If you have any questions or suggestions about this newsletter, please email Global Tax News Update Help at: globaltaxnewsupdatehelp@ey.com.

About Americas Tax Roundup

Published by NTD's Tax Technical Knowledge Services Group, Washington, D.C.
Jennifer Brittenham, writer and editor

Distributed weekly to all Americas Tax personnel.