On 29 April 2024, the Chamber of Deputies approved the bill that the executive branch had sent to Congress as a new draft of the “Bill of Bases and Points of Departure or the Freedom of Argentines,” along with the tax reform package.
The latest edition of our Field Guide to Going Global helps you examine foreign law issues for taking business models, products and technology international. Our guidance should be helpful whether you are working for a start-up company or a large multinational enterprise that is broaching new frontiers.
On 26 March 2024, the IRS Advance Pricing and Mutual Agreement (APMA) Program issued their 25th annual Advance Pricing Agreement (APA) report describing the experience, structure, and activities of the APMA Program during calendar year 2023. The report provides statistical information about the numbers of APA applications received and resolved during the year, including countries involved and transfer pricing methods employed. This article identifies key takeaways based on the data from the report and our experience advising companies during the APA process.
The Colombian Tax Office (“DIAN”) and the Superintendence of Companies have entered into an inter-administrative agreement for the exchange of information related to the Ultimate Beneficial Owner Registry, to strengthen the inspection and control functions of these entities and their investigative powers.
On 1 January 2022, the CFC rules became effective in Ukraine. For the novelty of the concept and the imperfections of the underlying legislation, many provisions of the applicable CFC rules call for clarification, elaboration, or further guidance.
In this context, on 2 May 2023, the Parliament of Ukraine passed – in the first (of typically two) readings – Bill No. 8137 “On Amendments to the Tax Code of Ukraine with respect to Enhancement of the Taxation of Controlled Foreign Companies” (“Amending Bill”), aimed at addressing most pressing issues pertaining to the application and interpretation of the CFC rules.
On 9 April 2024, Treasury released two sets of proposed regulations regarding the excise tax on repurchases of corporate stock under section 4501. The proposed regulations were published in the Federal Register on 12 April 2024. Comments are due on the procedural matters by 13 May 2024, but taxpayers have until 11 June 2024 to submit comments on the substantive guidance.
On 22 May 2024, the Swedish Parliament is expected to vote on a proposal to remove the requirement to retain original hard copy accounting materials. The bill, published on 29 February 2024, proposes that hard copy accounting materials, which have been duly saved digitally, no longer have to be kept in hard copy. The amendments are proposed to enter into effect on 1 July 2024.
The Brazilian Institute of the Environment and Renewable Natural Resources (IBAMA) established a new way of calculating the Environmental Control and Inspection Fee (TCFA) and, as of the first quarter of 2024, the economic size to be declared by subsidiaries will be the economic size of the parent company and the subsidiary jointly, considering the annual gross income of the legal entity as a whole for the basis for calculating this fee.
On 13 March 2024, the Brazilian IRS published Normative Instruction 2.180/24 (“IN 2.180/24”), which provides for the taxation of income earned by individuals resident in Brazil from non-interest-bearing deposits abroad, foreign currency held in kind, financial investments, controlled entities and trusts abroad, as well as the option to update the value of assets and rights abroad.
The long-awaited IN 2.180/24 regulates Law 14,754/23, which was passed on 12 December 2023 and brought important clarifications regarding the taxation by Income Tax of individuals (IRPF) with assets abroad.
On 27 March 2024, Decree No. 281/2024 (“Decree”) was published in the Official Gazette. The Decree extends the deadline for repatriating financial assets of at least 5% of the total value of assets located abroad from 31 March 2024 to 30 April 2024, inclusive.
As a reminder, the applicable personal assets tax rates for assets located abroad will be the same as those applicable to assets located in Argentina if, before 31 March of each year, taxpayers repatriate financial assets of at least 5% of the total value of assets located abroad and if certain additional requirements have been met.