This e-newsletter gives you an overview of international corporate tax developments being reported globally by KPMG member firms in the American Region between 1 March and 31 March 2012.
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Tax area concerned |
Relevant date / case reference |
Description of measures and publication link
(Considerations in italic where necessary) |
| Argentina |
| Proposed legislative changes and regulatory updates |
Customs |
2 March 2012 |
Businesses not reporting export activities cannot receive export refunds.
Read more |
| CIT |
26 March 2012 |
Business taxpayers should report financial activities in “real time”.
Read more |
| Administrative and case law |
CIT |
Fiat Concord S.A v. AFIP
6 March 2012 |
Interest-free loans (or loans with below-market interest rates) between members of the same corporate group may result in an income tax liability if it cannot be shown that the loan was made for the benefit of the party providing the loan.
Read more |
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| Brazil |
| Tax legislation adopted |
Financial transaction tax |
1 March 2012 |
As of 1 March 2012 financial transactions tax is also applicable to short-term foreign loans and bonds.
Read more |
| 15 March 2012 |
The financial transaction tax rate will be 6% on operations that have terms that are less than 1,800 days. For operations exceeding the five-year period, the applicable rate would be 0%.
Read more |
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| Canada |
| Proposed legislative changes and regulatory updates |
Budget |
29 March 2012 |
The 2012 Federal budget was published on 29 March 2012.
Read more |
| 20 March 2012 |
The 2012 Quebec budget was published on 20 March 2012.
Read more |
| 21 March 2012 |
The 2012 Saskatchewan Budget was published on 21 March 2012.
Read more |
| 27 March 2012 |
The 2012 New Brunswick Budget was published on 27 March 2012.
Read more |
| 27 March 2012 |
The 2012 Ontario Budget was published on 27 March 2012.
Read more |
| Tax legislation adopted |
CIT |
March 2012 |
Canadian-controlled private corporation can generally claim the small business deduction on rental income when that property is connected to the corporation's active business.
Read more |
| Treaties |
DTT |
9 March 2012 |
Protocol to income tax treaty with Austria.
Read more |
| 27 March 2012 |
New tax treaty with Italy and protocol to treaty with Switzerland enter into force.
Read more |
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| Colombia |
| Tax legislation adopted |
CIT |
31 July 2012 |
The deadline to register for annual tax incentives for investments in science, technology, and innovation projects has been extended to 30 March 2012.
Read more |
| Budget |
29 March 2012 |
Among the changes to Colombia’s business tax provision, are amendments to the “tax value unit,” tax incentive regimes, and certain administrative procedures for tax reporting (effective for 2012).
Read more |
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| Costa Rica |
| Administrative and case law |
VAT |
27 March 2012 |
Tax reform approval procedure: article 208bis of the legislative assembly regulations (i.e. providing for fast track review) is not contrary to the Constitution of Costa Rica.
Read more |
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| Guatemala |
| Proposed legislative changes and regulatory updates |
Income tax
VAT
Tax on vehicles
Revenue stamp tax |
5 March 2012 |
Legislative decree concerning the tax laws has been issued.
Read more |
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| Mexico |
| Tax legislation adopted |
Income tax |
28 December 2011 |
New provisions concerning supporting documentation for purposes of income tax deductions may affect non-Mexican entities doing business in Mexico.
Read more |
| Proposed legislative changes and regulatory updates |
Income tax
Foreign investment
Tax incentives |
2 March 2012 |
A proposal for the first resolution of amendments to the general tax rules for 2012 has been published.
Read more |
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| Panama |
| Proposed legislative changes and regulatory updates |
Budget |
2012 |
The 2012 tax reform has been published and concerns a.o. tax litigation and tax evasion, changes to the income tax return forms, transfer pricing, and international tax.
Read more |
| Proposed legislative changes and regulatory updates |
Income tax |
7 March 2012 |
An executive decree provides rules under the capital gains tax regime.
Read more |
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| USA |
| Proposed legislative changes and regulatory updates |
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For legislative changes and regulatory updates for the US please follow below link to the TaxNewsFlash United States.
Read TaxNewsFlash US |
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