| This week's tax news from the Americas - Canada sets entry-into-force date for Digital Services Tax
On 3 July 2024, an Order in Council (the OIC) established that Canada's Digital Services Tax Act (DSTA) comes into force 28 June 2024. Now that the DSTA is law and entered into force, consideration must be given to the potential implications of the new tax, including considering the "in-scope" revenue, developing the necessary processes to comply with the DSTA, and reviewing whether existing systems capture the information needed to calculate and report the new tax.
- Argentina enacts tax package
On 8 July 2024, the Argentine Government enacted, among other measures, the Special Incentive Regime for Large Investments (RIGI) and an amnesty regime for tax, customs and Social Security obligations that were due up to 31 March 2024. A separate amnesty regime applies for assets. Other changes include reducing the Personal Assets Tax from fiscal year 2023 onward.
- Brazil tax authorities rule on treatment of payments for right to commercialize or distribute software
In Private Letter Ruling No. 177, Brazil’s tax authorities (RFB) ruled that payments made abroad for the right to commercialize or distribute software are royalties for Brazilian tax purposes and, therefore, are subject to a 15% withholding tax. Further, the RFB ruled that payments for the right to distribute or license cloud-based platforms, without transferring source code, are not subject to the 10% Contribution for Intervention in the Economic Domain.
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| About Americas Tax Roundup Published by NTD's Tax Technical Knowledge Services Group, Washington, D.C. Jennifer Brittenham, writer and editor Distributed weekly to all Americas Tax personnel. | |