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 October and 31 October 2012.
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Tax area concerned |
Relevant date / Case reference |
Description of measures and publication link
(Considerations in italic where necessary) |
| Argentina |
| Tax legislation adopted and regulatory update |
Gross income tax |
1 October 2012 |
Argentina’s revenue service issued a resolution establishing new rates on gross income tax (ingresos brutos) that are effective 1 October 2012.
Read more |
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| Canada |
| Proposed legislation |
Withholding tax |
October 2012 |
Quebec proposes tax increase for mining corporations. Under the proposed changes the newly elected Quebec government would create a hybrid mining royalty regime based on both production values and profits.
Read more |
| Incentives |
1 January 2013 |
Companies that claim credits for scientific research and experimental development (SR&ED) may be affected by changes to this program coming as soon as 1 January 2013.
Read more |
| Tax legislation adopted and regulatory update |
Corporate income tax |
October 2012 |
The Canada Revenue noted that, when a partnership's activity which gave rise to a qualifying transitional income (QTI) reserve for its partners is no longer the partnership's principal activity, the CRA would deny the QTI reserve claimed by the corporate partners.
Read more |
| 2012 |
The 2012 federal budget tax measures are substantively enacted. The bill includes business and international tax measures from the 2012 federal budget.
Read more |
| October 2012 |
The Canada Revenue Agency issued a technical interpretation concerning the tax treatment of a series of shareholder loans and repayments.
Read more |
Federal Bill C-45, contains some important modifications to the foreign affiliate (FA) dumping proposals. Among other things, Bill C-45 introduces the concept of a ‘qualifying substitute corporation’, relaxes the paid-up capital (PUC) suppression rules and the pertinent loans or indebtedness rules, and modifies the indirect investment rules in a foreign affiliate — all of which alleviate some of the harsher results of these rules.
Read more |
| Dividend |
October 2012 |
The Canada Revenue Agency clarified that when only a portion of a dividend is designated as an ‘eligible dividend’ (as introduced in the 2012 federal budget), an online notice, press release, or a notice in an annual or quarterly report that an eligible dividend has been paid, is still an acceptable method of notification that a public corporation paid an eligible dividend.
Read more |
| Individual tax |
2013 |
There will be no individual tax changes for 2012—retroactive or otherwise. However, beginning in 2013, a new top tax bracket at 25.75% for income above $100,000 will be introduced.
Read more |
| Retail sales tax |
31 December 2012 |
The deadline to claim refunds to recover overpaid Ontario retail sales tax has been shortened this year to no later than 31 December 2012.
Read more |
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| Chile |
| Proposed legislation |
Corporate income tax |
October 2012 |
Taxpayers with activities or investments in Chile will likely be affected by significant changes to the country's tax regime that were enacted in late September 2012. One of the proposals includes an increase of the corporate income tax rate to 20%.
Read more |
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| Colombia |
| Proposed legislation |
Corporate income tax/VAT |
October 2012 |
A tax reform bill pending before the legislature includes proposed changes to the corporate income tax rate, the VAT rates, and income taxes for individuals. Read the overview or more detailed article. |
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| Costa Rica |
| Tax legislation adopted and regulatory update |
Personal income tax |
2013 |
The income tax rates and brackets for the 2013 tax year for salaried and self-employed individuals and ‘small companies’ were established by executive decree.
Read more |
| Reporting requirements |
October 2012 |
Changes to Costa Rica’s information tax return rules include clarifications on how information is to be reported.
Read more |
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| Mexico |
| Tax legislation adopted and regulatory update |
Reporting requirements |
October 2012 |
Mexico's tax administration published guidance pursuant to modifications to the third proposal to amend the tax law, including rules for official electronic tax invoices.
Read more |
| VAT |
October 2012 |
There is an ongoing discussion in Mexico about the VAT rate that is to apply with respect to food and drug consumption.
Read more |
| Corporate income tax |
October 2012 |
Mexico’s economic ministry published a list of export manufacturing and “maquila” business entities (industria manufacturer, maquiladora y de servicios de exportación—IMMEX) that have had their IMMEX participation canceled due to non-compliance.
Read more |
| Proposed legislation |
Federal labor law |
October 2012 |
Draft legislative amendments to provisions of Mexico’s federal labor law are now pending consideration by the Senate. Even though the legislative process is on-going, businesses need to be aware of certain points in the legislation that could affect the relationship between companies and their workforce.
Read more |
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| USA |
| Tax legislation adopted and regulatory update |
FATCA |
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The IRS issued FATCA timelines for due diligence.
Read more |
| - |
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For legislative changes and regulatory updates for the US please visit
TaxNewsFlash United States. |
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| Uruguay |
| Tax legislation adopted and regulatory update |
Reporting requirements |
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Uruguay’s central bank published requirements for registering title holders of equity participations.
Read more |
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