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International Tax

Newsletter

 

This e-newsletter gives you an overview of international tax developments being reported globally by KPMG member firms in the Americas Region between 1 December and 31 December 2013.

Argentina Canada Costa Rica USA
Barbados Cayman Islands Mexico  
Brazil Chile Panama  

For a full summary of global tax developments, visit kpmg.com/TaxNewsFlash.

To contact the International Tax Group email internationaltax@kpmg.com.

  Tax area concerned Relevant date Description of measures and publication link (Considerations in italic where necessary)
Argentina
Tax legislation adopted and regulatory update Transfer
pricing
3 January 2014 New guidance in Argentina requires taxpayers to report information about transactions between taxpayers and related parties and about contracts with foreign related parties.
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Consumption tax 3 December 2013 Argentina’s tax authorities on 3 December 2013 issued a resolution increasing the consumption tax rate to 35 percent (up from 20 percent) on purchases made abroad using credit, charge, or debit cards, or purchases made “online” including those from travel and tourism agencies.
Read more
Treaties DTT 1 January 2013 New laws published in Argentina’s official gazette concern the ratification and entry into force of a new income tax treaty between Argentina and Spain. The effective date of the new treaty’s provisions is a retroactive effective date beginning 1 January 2013.
Read more

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Barbados
Treaties DTT 17 December 2013 A protocol amending the income tax treaty between Barbados and Canada entered into force on 17 December 2013.
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Brazil
Tax legislation adopted and regulatory update Employees’ registration December 2013 The initial phase of an electronic registration system for employees has been launched in Brazil.
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Canada
Tax legislation adopted and regulatory update Treatment of automobile expenses 2014 Canada’s Department of Finance announced that the automobile expense deduction limits and the prescribed rates for the automobile operating expense benefit will remain unchanged for 2014.
Read more
Indirect tax compliance December 2013 Many businesses—including those that provide taxable benefits or pension plans to their employees—soon will have to take into account recent changes to the GST/HST as the businesses prepare to meet upcoming tax compliance deadlines such as filing returns, making elections, and remitting indirect taxes.
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Tax accounting December 2013 Those involved in preparing financial reports for corporations or other organizations need to be aware of certain 2013 Canadian income tax changes that may need to be reflected in year-end financial statements under International Financial Reporting Standards (IFRS), Accounting Standards for Private Enterprises (ASPE) or U.S. generally accepted accounting principles (U.S. GAAP).
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Dividend taxation 1 January 2014 Legislation in Prince Edward Island that increases the tax rate on non-eligible dividends to 38.74 percent (up from 38.56 percent) received Royal Assent on 8 December 2013.
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Income tax 2013 Legislation in Canada containing the remaining tax measures from the 2013 federal budget, as well as certain other previously announced tax measures, received Royal Assent on 12 December 2013.
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Various taxes 2013 Legislation enacting Manitoba’s 2013 budget measures received Royal Assent on 5 December 2013.
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Tax compliance 2013 Corporations must list revenue earned from webpages or websites on a new, separate schedule.
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Tax compliance/ taxpayer relief 31 December 2013 Taxpayers have until 31 December 2013 to file a request for taxpayer relief (i.e., the “old fairness” provision) for:
the 2003 tax year
any reporting period that ended during the 2003 calendar year
any interest and certain penalties that accrued during the 2003 calendar year, for any tax year or reporting period.
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Taxation of owner-managers 2013 There may be tax planning opportunities for owner-managers in Canada that are still available before the year ends.
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R&D End of 2013 R&D companies in Canada eligible for tax credits under the federal government’s scientific research and experimental development (SR&ED) program may want to incur upcoming expenditures before the end of 2013 because the general SR&ED tax credit rate will be reduced to 15 percent (from 20 percent) starting in 2014.
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Pension plans 2014 The Canada Revenue Agency announced the 2014 contribution limits for the following pension plans:
Money Purchase Registered Pension
Registered Retirement Savings Plans
Deferred Profit Sharing Plans.
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Proposed legislation Treaty shopping 2014 Foreign-based multinationals and foreign corporations investing in or through Canada will want to closely follow developments now that the Department of Finance has ended its formal consultations on possible measures to combat “treaty shopping” abuses and the related erosion of Canada’s tax base. The government’s final proposal could appear sometime in 2014, perhaps as early as the 2014 federal budget.
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Pension plans 1 July 2014 Quebec has passed legislation to create a voluntary retirement savings plans—the province's version of pooled registered pension plans.
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Labor-Sponsored Venture Capital Corporations 27 January 2014 Canada’s Department of Finance released draft legislation to provide transitional relief for taxpayers affected by the phase-out of the federal Labor-Sponsored Venture Capital Corporations tax credit by 2017.
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Various taxes November 2013 Legislation in Quebec, that would codify items and harmonization measures from various information bulletins, received first reading in the Quebec legislature in November 2013.
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R&D November 2013 The Quebec government issued an information bulletin in early November 2013, announcing that it will harmonize with certain R&D measures in the 2012 federal budget.
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Treaties DTT 17 December 2013 A Protocol amending the income tax treaty between Barbados and Canada entered into force on 17 December 2013.
Read more
Exchange of information December 2013 Recent tax treaty and tax agreement developments in Canada include the following:
a Protocol to the Canada-Luxembourg income tax treaty entered into force 10 December 2013, and allows for the OECD standard for the exchange of tax information
a tax information exchange agreement with Panama entered into force on 6 December.
Read more
Comprehensive Economic and Trade Agreement December 2013 Canada and the European Union entered into a Comprehensive Economic and Trade Agreement (CETA) that is intended to:
remove tariffs on goods that are produced in Canada or the EU and shipped directly to one party from the other
remove approximately 98 percent of all tariffs on goods moving between Canada and the 28 EU countries
provide Canadian companies with preferential market access to the EU’s more than 500 million consumers.
Read more
Other Treaty shopping December 2013 In response to the Canadian government’s consultation paper on treaty shopping, the KPMG member firm in Canada made a submission of items that the Department of Finance might consider in determining whether a separate treaty shopping measure is required or appropriate at this time.
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Cayman Islands
Treaties FATCA 29 November 2013 The U.S. Treasury Department posted text of a FATCA intergovernmental agreement between the United States and the Cayman Islands. The agreement is dated 29 November 2013.
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Chile
Tax legislation adopted and regulatory update Income tax 2012 Chile’s tax administration issued guidance to implement certain income tax measures relating to the treatment of corporations and partnerships and to the treatment of certain employee benefits.
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Costa Rica
Treaties FATCA November 2013 The U.S. Treasury Department in late November 2013 posted text of a FATCA intergovernmental agreement between the United States and Costa Rica.
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Mexico
Tax legislation adopted and regulatory update Various taxes 1 January 2014 The last economic legislative package including tax reform provisions was published in Mexico’s official gazette.
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Proposed legislation Energy taxation December 2013 The president of Mexico has proposed energy reform measures.
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Panama
Tax legislation adopted and regulatory update DTT December 2013 Panama’s tax authorities have issued guidance for taxpayers to follow if they are seeking to apply for tax benefits available under one of Panama’s income tax treaties.
Read more
Treaties TIEA 6 December 2013 A tax information exchange agreement between Panama and Canada entered into force on 6 December 2013.
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USA
Tax legislation adopted and regulatory update For legislative changes and regulatory updates for the US please visit below link to the TaxNewsFlash United States.
Read TaxNewsFlash US
Proposed legislation Transfer pricing November 2013 The IRS in late November 2013 released two notices containing draft revenue procedures providing guidance and instructions with respect to requesting competent authority assistance and advance pricing agreements.
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