06 January 2025

Americas Tax Roundup | 6 January 2025

 
 

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

 
 
      
 

     This week's tax news from the Americas

  • US taxpayers may elect simplified and streamlined approach to intercompany transactions beginning in 2025
    In Notice 2025-04 (Notice), the Treasury Department and IRS announced their intent to issue proposed regulations and other guidance on applying the simplified and streamlined approach (SSA) of the Organisation for Economic Co-operation and Development for pricing certain controlled transactions involving baseline marketing and distribution activities. Taxpayers subject to US tax on in-scope transactions may rely on the Notice and elect to apply the SSA for tax years beginning on or after 1 January 2025.
  • Brazilian Congress approves Bill of Law introducing OECD Pillar Two rules
    On 18 December 2024, the Brazilian Congress approved Bill of Law 3,817, which implements Pillar Two rules in the country. The Bill of Law introduces a qualified domestic minimum top-up tax (QDMTT) but does not include the income inclusion rule (IIR) or the undertaxed payments rule (UTPR). The Brazilian QDMTT rules largely align with the global anti-base erosion (GloBE) model rules and are scheduled to take effect for fiscal years starting on or after 1 January 2025.
  
 
 

     This week's newsletters

  
 
 

     Upcoming EY webcasts

A calendar of all upcoming EY webcasts is available.

  
 
 

     Recent EY podcasts

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

     Africa

     Asia

     Europe

     Middle East

  
 
 
 

Additional resources

EY Global Tax News Update
EY's Global Tax Alerts and other content can be delivered directly to your inbox. Register for EY's Global Tax News Update.

EY Guides available for download
Browse our in-depth guides covering corporate tax, indirect tax, personal taxes, TP and other tax matters in more than 150 countries.

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

 
 
 
 

About Americas Tax Roundup

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

Distributed weekly to all Americas Tax personnel.

 
 

Document ID: 2025-0123