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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 January and 31 January 2014.

Argentina Dominican Republic Mexico USA
Brazil Jamaica Panama  
Canada Latin America Peru  

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 Income tax on exports 7 January 2014 Argentina’s tax administration issued a resolution establishing a new income tax (Impuesto a las Ganancias) on transactions that export goods to a foreign jurisdiction other than the foreign jurisdiction billed for the transaction. The provisions apply to export transactions starting 7 January 2014.
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Transfer pricing 31 December 2013 A resolution issued by the tax administration of Argentina expands on the criteria for identifying jurisdictions to be included in the “white list” of countries for which the transfer pricing rules will not apply.
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A “white list” of jurisdictions or countries for which Argentina’s transfer pricing rules will not apply was published by the Argentine tax authority.
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Brazil
Tax legislation adopted and regulatory update Income tax on employee profit-sharing plan payments 2014 Brazil’s tax administration published guidance setting forth the income tax rates on payments from employee profit-sharing plan during 2014.
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Canada
Tax legislation adopted and regulatory update FATCA 25 April 2014 FATCA is a complex, new reporting and withholding regime enacted to encourage U.S. persons to disclose their offshore accounts, investments, and income. FATCA imposes material U.S. tax documentation, reporting, and withholding requirements on foreign (non-U.S.) financial institutions—including Canadian funds, Canadian private equity, and Canadian pension funds.
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GST/HST 31 January 2014 Employers that offer registered pension plans to their employees must calculate an amount of deemed GST/HST and QST (if applicable) and remit these amounts, in their monthly December 2013 GST/HST and QST returns—i.e., returns that are due by 31 January 2014.
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Tax evasion & aggressive tax avoidance January 2014 The Canada Revenue Agency launched an informant's hotline as part of its Offshore Tax Informant Program, intended to focus on international tax evasion and aggressive tax avoidance.
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Tax compliance January 2014 The Canada Revenue Agency announced a new approach to improving tax compliance by small and medium sized businesses.
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Interest rate for deemed interest-income inclusion 1 January-31 March 2014 The Canada Revenue Agency confirmed that the quarterly prescribed interest rate that is used to determine the deemed interest-income inclusion from a “pertinent loan or indebtedness” will be 4.94 percent for 1 January 2014 through 31 March 2014.
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Employer health tax 1 January 2014 Ontario’s Employer Health Tax Act has been amended and, among other changes, includes an increase in the exemption threshold that applies for employers with an annual payroll in excess of CAN$450,000 as of 1 January 2014.
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Tax assessment 2014 Canada Revenue Agency announced it would continue its policy of putting “on hold” the assessments and refunds of tax with respect to returns filed by taxpayers participating in “gifting tax shelters” until the audit of the tax shelter is complete.
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Dividend taxation 2014 The Alberta Treasury Board and Finance announced that the 2014 provincial tax rate on non-eligible dividends will remain unchanged and will remain at the 2013 levels.
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Proposed legislation GST/HST 25 January2014/ 22 March 2013 The Department of Finance announced proposed GST/HST exemptions for qualifying public hospital parking on 25 January 2014. Based on the proposed amendments, qualifying parking provided by a public hospital will be exempt from GST/HST effective 25 January2014. In addition, qualifying hospital parking provided by a charity (that is not a public hospital) will be GST/HST exempt retroactive to 22 March 2013.
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Federal Budget 11 February 2014 The Finance Minister of Canada announced that the Conservative government’s 2014 federal budget will be delivered on 11 February 2014. Tax professionals in Canada expect a range of tax measures in this year’s budget, with the government maintaining its focus on tax fairness measures and tightening the tax system by closing “tax loopholes.”
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Tax compliance 2013 Canada’s Department of Revenue released draft legislation to implement 2013 federal budget proposals, to require certain financial intermediaries to report international electronic funds transfers of CAN$10.000 or more to the Canada Revenue Agency.
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Administrative and case law Transfer pricing McKesson Canada Corp. v. The Queen 2013 TCC 404 (20 December 2013) Canadian multinational companies may want to note the implications of a recent transfer pricing case in which the Tax Court of Canada held for the tax authority concerning what constitutes a reasonable discount rate in a non-arm’s length accounts receivable factoring arrangement.
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Treaties DTT 30 December 2013 A Protocol amending the income tax treaty between Canada and France entered into force 30 December 2013.
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Dominican Republic
Tax legislation adopted and regulatory update Tax rules for investment funds January 2014 The Dominican tax authorities issued General Ruling 05-2013 concerning the tax (fiscal) requirements, obligations, duties, and procedures that investment fund management companies and investment funds must comply with regardless of whether they operate—directly or indirectly—in the Dominican Republic.
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Jamaica
Tax legislation adopted and regulatory update Tax compliance 15 March 2014 Taxpayers who have not filed their income tax returns for the year 2013 and declarations of estimated income tax for the year 2014 need to remember that the deadline for filing these documents is 15 March 2014.
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Latin America
Other Tax revenue data 1990-2012 The OECD released its third edition of Revenue Statistics in Latin America 1990-2012, providing a detailed analysis of tax revenue data collated over the past decade across Latin America.
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Mexico
Tax legislation adopted and regulatory update Various taxes 2014 An omnibus tax bill (Resolución Miscelánea Fiscal) for 2014 was published in the official gazette on 30 December 2013 and includes various provisions.
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VAT/IEPS compliance December 2013 Companies operating under the IMMEX or maquiladora regime must demonstrate that they meet certain requirements and that they have obtained certification concerning certain imports under changes to the rules for Mexico’s VAT and special tax on production and services (impuesto especial sobre producción y servicios—IEPS) for the companies to be eligible for a credit of the VAT or IEPS.
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Various state & local taxes 2014 While the focus on tax reform in Mexico generally has been on federal taxation, taxpayers must not overlook the effects of state-level tax actions. Some Mexican states have focused on increasing the collection of taxes on sales of certain products (including alcohol, lottery and raffle tickets), hospitality services, and payroll tax.
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Tax incentives 1 January 2014 Various tax incentives for entities in the Industria Manufacturera, Maquiladora y de Servicios de Exportacion sector are effective 1 January 2014.
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Panama
Tax legislation adopted and regulatory update Transfer pricing 30 June 2014 Taxpayers in Panama are required to present to the tax authorities an annual transfer pricing report (Form 930) and a related transfer pricing study. The transfer pricing report and study for the tax year ending on 31 December 2013 are due before 30 June 2014.
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Income tax system 10 January 2014 A new law in Panama repeals the recently enacted worldwide tax system and replaces it with the prior territorial income tax system.
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Peru
Tax legislation adopted and regulatory update Frequent importers regime 26 January 2014 Peru’s tax administration on 11 January 2014 issued a resolution establishing changes to the “frequent importers” regime (Relación de Importadores Frecuentes).
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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

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Publication Number: 131012