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

     This week's tax news from the Americas

• Brazilian Government proposes to increase combined corporate income tax rate and withholding tax on INE payments
  On 30 August 2024, the Brazilian Government submitted to the Congress a bill that would increase certain income taxes as part of its efforts to avoid increasing the budgetary deficit. The bill would modify the social contribution on net profits (a component of the corporate income tax) and interest on net equity (INE) rules. The changes would apply as of 1 January 2025, if enacted.

• Brazilian Federal Revenue Service publishes public consultation on proposed transfer pricing regulations applicable to intragroup services and advance pricing arrangements
  On 28 August 2024, the Brazilian Federal Revenue Service (RFB) published a public consultation to collect comments on proposed regulations implementing transfer pricing legislation (Law No. 14.596/23). The regulations address (1) transactions involving intragroup services, and (2) advance pricing agreements. Taxpayers may submit comments by email until 30 September 2024 and may request meetings with the RFB to discuss the proposed regulations.

• Canada Department of Finance releases revised legislative details to implement changes to increase capital gains inclusion rate
  Canada’s Department of Finance released several packages of draft legislative proposals for public comment on 12 August 2024, including the much-anticipated revised draft legislative proposals to implement changes to increase the capital gains inclusion rate (the August proposals). The government announced in the notice of ways and means motion (NWMM) and two accompanying backgrounders issued on 10 June 2024 (the June proposals) that further technical or consequential changes would be introduced this summer, but those changes would not materially affect the design of, or introduce new features to, the measures in the NWMM. Although the August proposals are generally consistent with this statement, taxpayers should nonetheless be aware that certain changes included in the August proposals could impact the tax consequences of recognizing capital gains in certain circumstances.

• Argentina reduces tax rates on certain purchases of foreign currency
  On 1 September 2024, the Argentine National Executive Branch published Decree 777, which reduces the tax rate from 17.5% to 7.5% on certain purchases of foreign currency for the payment abroad of certain goods and services.

• Peru implements VAT Registry for online platforms and nonresident providers of digital services
  In Resolution 000173–2024, the Peruvian Tax Authority established rules for implementing the Value-Added Tax (VAT) Registry for online platforms and nonresident providers of digital services. Nonresident providers must register for the VAT Registry online.

     This week's newsletters

• Report on recent US international tax developments - 6 September 2024
  Our weekly report with brief summaries of all the week's US international tax developments and related activity.

     Upcoming EY webcasts

• 10 September: BEPS 2.0: What to expect from ongoing Pillar One and Two developments
• 12 September: Securing critical assets: navigating geopolitical compliance
• 17 September: How SAP RDP is addressing sustainability compliance and circularity
• 20 September: Tax in a time of transition: legislative, economic, regulatory and IRS developments - September 2024
• 24 September: Accounting for income taxes: a quarterly perspective - September 2024
• 26 September: What Q3 IFRS Quarterly Tax Developments could impact tax accounting

A calendar of all upcoming EY webcasts is available.

     Recent EY podcasts

• EY Podcast | Weekly US international cross-border taxation news for week ending 6 September 2024
• EY Podcast | EY Transfer Pricing Roundup - Singapore Transfer Pricing update (4 September 2024)

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

• Brazil simplifies document requirements for foreign investors and other qualifying residence permit applicants
• Curacao and Republic of Suriname enter treaty for elimination of double taxation on income and capital
• New visa requirement for visa nationals transiting through Brazil

     Africa

• Kenya High Court rules club entrance and subscription fees are exempt from VAT
• Mauritius introduces new permit for highly skilled professionals and reduced salary threshold for Occupation Permit applicants

     Asia

• Pakistan announces new visa-free policy for residents of China Mainland
• Pakistan implements new visa policies for business visitors from several countries

     Europe

• Germany expects application processing delays due to reform to citizenship laws
• German Federal Tax Court rules that German dividend withholding tax must be refunded to nonresident funds
• Ireland’s new Employment Permits Act 2024 goes into effect

     Middle East

• Bahrain issues domestic minimum top-up-tax legislation
• Saudi Arabia announces 15th wave of Phase 2 e-invoicing integration
• Turkiye announces new visa-free policy for qualifying Iraqi business visitors

     Oceania

• Australia and New Zealand continue to focus on compliance during paced immigration reform
• New Zealand proposes generic emergency response tax relief measures and other changes

      This week's EY publications

     Banking & Capital Markets

• How auto lenders can reimagine themselves today for a world of change

     Oil & Gas

• Why cost discipline and consolidation inspire confidence in oil and gas

     Power and Utilities

• Cybersecurity transformation: a new operating model for utilities

     Legislation

• Expiration and change dates of various tax provisions may increase focus on tax policy

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.