07 October 2024 Americas Tax Roundup | 7 October 2024 | | A weekly summary of the top weekly tax news, trends and developments in the Americas | | | | | | | | | | This week's tax news from the Americas - Canada | Reminder for distributed investment plans - request investor information by 15 October
Distributed investment plans (DIPs) that are selected listed financial institutions must request certain information from investors by 15 October 2024. DIPs generally include mutual fund trusts and certain partnerships. The information provided by the investors is used to calculate the DIP's provincial attribution percentage and the DIP's net tax liability/refund for Goods and Services Tax/Harmonized Sales Tax/Quebec Sales Tax. If a DIP does not request this information by 15 October 2024, certain investors may be deemed to be residents of the highest-rate province (i.e., 15%), possibly resulting in higher tax liabilities or lower refunds for the DIP.
- Argentina publishes decree implementing Incentive Regime for Large Investments
The Argentine National Executive Branch published, in the Official Gazette, Decree 749, which implements the Incentive Regime for Large Investments (RIGI), established in Title VII of Law No. 27,742 (Bases Law or the Law). The decree details the sectors to which the RIGI will apply, including the definition of each sector, and establishes the minimum investment amounts in computable assets per sector and subsector.
- US IRS representatives say IRS will evaluate transfer pricing documentation and method when deciding on penalties
US IRS representatives have recently addressed the IRS's current approach to asserting penalties in transfer pricing cases, saying that both the documentation and method of transfer pricing must pass muster. On 18 September 2024, Michelle Ng, IRS Office of Associate Chief Counsel (International) attorney, said that taxpayers should consult IRS FAQs on transfer pricing documentation so they can understand what the IRS is requesting. In addition to documentation backing up a taxpayer's position, however, the chosen method of transfer pricing must also be reasonable, she said.
- Uruguay extends application of reduced VAT rate for tourism sector until 30 April 2025
Through Decree No. 256/024, Uruguay’s Ministry of Economy and Finance has extended from 30 September 2024 to 30 April 2025, the 9% value-added tax (VAT) rate reduction for certain tourism activities, provided the payment is made with a credit card, debit card or e-money payment instrument. This initiative aims to support the tourism sector by providing financial incentives for transactions made through electronic payment methods.
- Uruguay ratifies the double taxation treaty with Colombia
On 23 September 2024, Uruguay ratified the double taxation treaty between Uruguay and Colombia, which both countries had signed on 19 November 2021. The DTT will come into force once it is ratified by the Colombian Parliament and the corresponding notifications are exchanged between the countries.
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Document ID: 2024-1824 |