06 October 2025 Americas Tax Roundup | 6 October 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 expands export controls to include 50% 'Affiliates Rule' for restricted parties
The US Department of Commerce, Bureau of Industry and Security, on 30 September 2025, published an Interim Final Rule establishing a "50% Affiliates Rule," resulting in a major and immediate expansion of US export controls. The rule is expected to significantly affect companies' compliance programs. Under the new rule, any entity that is 50% or more owned (directly or indirectly, individually or in aggregate) by one or more entities on the Entity List is automatically subject to the same export restrictions as the listed ownership entity.
- US Trade developments include new tariffs on pharmaceuticals, Section 232 investigations into certain imports
On 25 September 2025, US President Trump informally announced new tariffs, effective 1 October 2025, including a 100% tariff on branded pharmaceuticals unless production is underway in the United States. Tariffs of 50% apply to kitchen cabinets, while 30% tariffs apply to upholstered furniture. Separately, the US Department of Commerce initiated Section 232 investigations into imports of robotics, industrial machinery, personal protective equipment and medical equipment, with a comment period ending on 17 October 2025.
- Argentine Tax Authorities implement new procedure to recover the Impuesto PAIS
On 25 September 2025, the Argentine Revenue and Customs Control Agency (ARCA) published General Resolution No. 5,765/2025, establishing Phase 2 of the refund procedure for Impuesto PAIS payments on imports of goods, effective from 6 October through 19 November 2025. The new procedure applies to payments of Impuesto PAIS related to imports of goods registered through 12 December 2023 and those from 13 December 2023 to 24 November 2024, that meet certain requirements.
- Argentina's MLI enters into force on 1 January 2026
On 29 September 2025, Argentina deposited with the Organisation for Economic Co-operation and Development (OECD) the ratification instrument for the "Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting" (MLI). With this step completed, the MLI will enter into force for Argentina on 1 January 2026. Multinational companies with a presence in Argentina should consider the changes the MLI introduces to the existing network of double tax treaties and assess the possible consequences for their cross-border transactions.
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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: 2025-2013 |