| | This week's tax news from the Americas - Canada's 2025 budget implementation bill no. 1 introduced in House of Commons
On 18 November 2025, Bill C-15, Budget 2025 Implementation Act, No. 1, was introduced in the House of Commons, implementing various tax measures announced in the 2025 federal budget, the 2024 federal fall economic statement, and various previously announced measures included in draft legislation released in recent years. Key provisions include the reinstatement of the accelerated capital cost allowance for capital properties, enhancements to the scientific research and experimental development program, and significant amendments to Canada's transfer pricing rules.
- Argentina proposes amendments to its transfer pricing regime
The Argentine tax authority proposed a new draft General Resolution that would replace existing regulations and fundamentally reshape the country's transfer pricing regime for fiscal years ending on or after 31 December 2025. The draft introduces tighter rules on the use of comparables, mandatory justification for changes in transfer pricing methods and enhanced requirements for documentation, particularly for international transactions and business restructurings. Notable changes include new definitions for hard-to-value intangibles, clear guidelines for export commodity contracts, updates to de minimis thresholds and revised procedures for submitting the Master File and compliance risk questionnaires. The draft will be available for comments until 12 December 2025.
- G20 Leaders' Declaration reflects continued engagement to address Pillar Two concerns
In the declaration issued following the summit on 22-23 November 2025 in Johannesburg, South Africa, the G20 leaders expressed support for continued engagement around Pillar Two global minimum taxes, reiterating the desire to find a balanced and practical solution acceptable to all and noting the role of the OECD/G20 Inclusive Framework in advancing these efforts.
- OECD releases update to Model Tax Convention
On 19 November 2025, the Organisation for Economic Co-operation and Development (OECD) released an update (the 2025 Update) to the Model Tax Convention on Income and on Capital (OECD MTC) and its Commentary. Key changes include clarifications on when cross-border remote working (such as from a home office) creates a taxable presence for a business, a new alternative provision on how income from activities connected with the exploitation and extraction of natural resources should be taxed, and other updates aimed at ensuring consistency in treaty interpretation and enhancing tax certainty. The 2025 Update also reflects amendments made to the observations and reservations of OECD Member countries and the positions of non-Members with respect to the OECD MTC and its Commentary.
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| | 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. | |
