15 September 2025 Americas Tax Roundup | 15 September 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 Supreme Court will hear oral arguments in tariff case in early November 2025
The US Supreme Court, on 9 September 2025, granted certiorari and a motion to expedite oral argument in Trump, et al. v. V.O.S. Selections, Inc., et al., the case challenging the legal basis for President Trump's Reciprocal Tariff Policy. The case follows a 29 August 2025 decision by the US Court of Appeals for the Federal Circuit, which held that President Trump exceeded his authority under the International Emergency Economic Powers Act in imposing certain tariffs.
- Colombia's Executive Branch submits 2026 tax reform bill to Congress
On 1 September 2025, the Colombian government submitted to the Congress a tax reform bill (Financial Law) aimed at addressing a gap of 26.3 trillion Colombian Pesos (approximately US$6.5b) in the 2026 budget law, which is also currently under discussion in the Congress. The bill proposes a permanent 15% surtax on corporate income tax for financial institutions, increases from 3% to 5% the tax on nonresident tax filers with significant economic presence, and increases from 20% to 30% the withholding tax on dividends paid to nonresidents. It also would change the holding period to apply the reduced 15% capital gains rate on the transfer of fixed assets.
- Chile concludes software program reseller payments qualify as business profits under Chile-US tax treaty
In Ruling No. 1611/2025 (issued 14 August 2025), Chile's tax authority concluded software program payments made by a Chilean company to US providers under a reseller agreement qualify as business profits under Article 7 of the Chile-US tax treaty, as long as the US provider is a resident under Article 4 and meets the limitation on benefits criteria under Article 24. Therefore, those payments are not subject to Chilean withholding tax, unless the US provider has a permanent establishment in Chile.
- Uruguay presents bill proposal for the National Budget 2025--2029
On 31 August 2025, the Uruguayan Executive Branch submitted to Parliament the National Budget Bill for the period 2025–2029, proposing significant tax changes effective from 1 January 2026, including the introduction of a domestic top-up minimum tax. Other proposals include taxing capital gains from foreign assets for individuals and revising the in-patriate regime for individuals, which would offer new tax residents a full exemption on foreign capital gains for 10 years, followed by a preferential 50% tax rate for five years.
- Uruguay regulates food donations and grants tax incentives
On 20 August 2025, Uruguay’s Ministry of Economy and Finance issued Decree No. 179/005, which regulates Law No. 20,177 on the donation of food for human consumption and the tax incentives for those donations. Donors may include public or private entities engaged in the production, processing, packaging, storage, distribution or marketing of food, including the cultivation of food products, production of food and beverages (excluding distilled alcoholic beverages), and wholesale or retail trade of food and beverages. Tax incentives include a corporate income tax deduction for donations up to 2% of gross income or 5% of taxable net income and a full value-added tax deduction on the acquisition of donated food items.
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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: 2025-1849 |
