A weekly summary of the top weekly tax news, trends
and developments in the Americas

     This week's tax news from the Americas

• United States President-elect discusses tariffs on Canada and Mexico, and additional tariffs on China
  United States (US) President-elect Donald Trump published on TRUTH social (a social media platform owned by Trump Media & Technology Group) that one of his first executive orders will be to impose a 25% tariff on all products imported into the United States from Mexico and Canada. Trump added that these tariffs would remain in place until the countries intensify efforts to combat drugs and illegal immigration. Trump also discussed imposing an additional 10% tariff on Chinese products, on top of the tariffs already in place, until it is concluded that China has taken a stronger stance on the issues of drugs crossing into the United States from the Mexico border.

• Canada proposes temporary GST/HST relief for holiday essentials
  On 21 November 2024, Canada announced it will introduce legislation to provide temporary relief from the Goods and Services Tax/Harmonized Sales Tax (GST/HST) on holiday essentials, such as groceries, restaurant meals, children's clothing and footwear, and children's toys. If enacted, relief would apply from 14 December 2024 through 15 February 2025. Given that the onset of the relief period is fast approaching, retailers should prepare by reviewing their inventories and adjusting their point-of-sale software as soon as possible.

• Canada's clean technology manufacturing investment tax credit - an update
  The Department of Finance released for public comment draft legislative proposals on the clean technology manufacturing investment tax credit (ITC), which would clarify and expand the existing rules. The draft legislative proposals are generally consistent with previous announcements and include various technical amendments.

• Canada Border Services Agency initiates anti-circumvention investigation into dumping/subsidizing of certain container chassis from China
  On 25 November 2024, the Canada Border Services Agency (CBSA) initiated its first anti-circumvention investigation under the Special Import Measures Act. This investigation targets the alleged circumvention of duties on certain container chassis from the People’s Republic of China.

• Canadian International Trade Tribunal issues finding on pea protein imports from People's Republic of China
  The Canadian International Trade Tribunal (CITT) found that the dumping and subsidizing of certain pea protein originating in or exported from the People's Republic of China has injured the domestic industry. Certain exporters were excluded from the finding.

• Canadian International Trade Tribunal continues its finding on corrosion-resistant flat-rolled steel sheet products from China
  On 20 November 2024, the CITT ordered the continuation of its previous inquiry into the dumping of corrosion-resistant flat-rolled steel sheet products of carbon steel originating in or exported from the People's Republic of China, the Separate Customs Territory of Taiwan, Penghu, Kinmen and Matsu, the Republic of India and the Republic of Korea. Anti-dumping duties will continue to apply to the subject goods for as long as the CITT's order remains in effect.

• Argentina eliminates prepayments for the Impuesto PAIS for imports of goods
  Argentina's Revenue and Customs Control Agency issued General Resolution 5604/2024 on 26 November, eliminating the 95% prepayment that had been required for the Impuesto PAIS (i.e., tax rates on purchases of foreign currency for the payment abroad of certain goods and services).

• Bermuda releases additional FAQs for guidance on corporate income tax regime
  The Government of Bermuda released additional guidance in the form of frequently asked questions (FAQs) on certain determinations under the Corporate Income Tax Act (CIT Act). The four new FAQs provide guidance on how to interpret certain provisions and legislation that are forthcoming.

• Cyprus tax authorities issue clarification note regarding Bilateral Agreement with the United States
  The Cypriot Tax Department has publicly announced that the bilateral Competent Authority Agreement (CAA) for the exchange of country-by-country reports between Cyprus and the United States (US), which is still under negotiation, is expected to be effective for reporting fiscal years starting on or after 1 January 2024, absent further modifications.

• OECD's 2023 mutual agreement procedure statistics show continued strength in the US program
  On 15 November 2024, the OECD released MAP statistics showing the US MAP program's open inventory of cases decreased modestly for transfer pricing cases, but increased for non-transfer pricing cases in 2023. The US MAP program closed 230 cases (that were started on or after 1 January 2016) and opened 247 new cases in 2023. For global statistics, see Tax Alert 2024-2124.

• G20 Leaders stress importance of progressive taxation and reiterate their commitment to BEPS 2.0
  On 18-19 November 2024, G20 Leaders met in Rio de Janeiro, Brazil, to address major global challenges and promote strong, sustainable, balanced and inclusive growth. The meeting concluded with the release of the Rio de Janeiro Leaders’ Declaration, which includes a brief section on international tax priorities.

     This week's newsletters

• Report on recent US international tax developments - 6 December 2024
  Our weekly report with brief summaries of all the week's US international tax developments and related activity.

• TaxMatters@EY | December 2024
  Our monthly Canadian summary to help you get up to date on recent tax news, case developments, publications and more.

• Trade Talking Points | Latest insights from EY's Trade Strategy team - November 2024
  Our monthly report with the latest insights from EY's Trade Strategy team.

     Upcoming EY webcasts

• 9 December: 2024 Asset management tax year-end webcast: Year-end tax considerations and other hot topics for alternative asset managers
• 11 December: Year-end US information reporting changes: What filers need to know this season to prepare for changes and updates to IRS reporting requirements
• 12 December: Preparing your operating model for potential trade shifts
• 13 December: Tax in a time of transition: Legislative, economic, regulatory and IRS developments
• 17 December: Accounting for income taxes: A quarterly perspective
• 18 December: Sustainability Tax webcast series: Circularity and tax function strategy
• 19 December: How Q4 IFRS Tax Developments can impact tax accounting

A calendar of all upcoming EY webcasts is available.

     Recent EY podcasts

• EY Podcast | Weekly US international cross-border taxation news for week ending 6 December 2024
• EY talks tax | International tax talk - 12 November 2024
• EY talks tax | Special post-election edition: Tax in a time of transition – 8 November 2024
• EY talks tax | BorderCrossings … with EY transfer pricing and tax professionals – 31 October 2024

All episodes of the EY Cross-Border Taxation Spotlight and
EY Talks Tax are available through Apple podcasts.

      This week's EY Global Tax Alerts

     Americas

• Colombia announces temporary process change amid ongoing delays in issuance of foreigner IDs
• Costa Rica updates list of regions at risk of yellow fever transmission

     Africa

• Egypt advances VAT reform by canceling VAT on certain exported services
• Kenyan Court of Appeal declares Insurance Regulatory Authority's powers include price regulation
• Kenya Revenue Authority issues comprehensive guidance on MAP in resolving international tax disputes
• Kenya Tax Appeals Tribunal determines Resale Price Method is most appropriate TP method for company's marketing operations

     Asia

• China Mainland announces updates to its visa-free policies for certain jurisdictions

     Europe

• Belgium to increase salary thresholds effective 1 January 2025
• Denmark extends the Special Act on displaced persons from Ukraine until 17 March 2026
• Denmark introduces stricter requirements for foreign service providers
• EMEIA private equity tax topics update for Q3/Q4 2024
• European Court of Justice holds relocating production won't enable company to escape additional duties unless relocation is economically justified
• European Commission adopts final implementing regulation on template and electronic reporting formats for public CbCR
• EU Council adopts trade, import and export ban on products made using forced labor
• EU Deforestation Regulation | Insights into proposed changes and latest guidance
• Hungary publishes draft GloBE Registration forms
• Ireland announces relaxed travel guidelines for the Christmas holiday period
• Italy issues draft legislation for corporate income tax reform
• Italian Tax Authority circular letter provides clarifications on Investment Management Exemption regime
• Netherlands announces temporary re-introduction of internal border controls
• Netherlands proposes restrictions on assignment of highly skilled foreign nationals by Dutch companies
• Poland publishes Minister of Finance General Ruling on Parent-Subsidiary Directive Subject-to-Tax Requirement for dividends exemption
• Saudi Arabia announces 18th wave of Phase 2 e-invoicing integration
• Swedish parliament approves new EU Blue Card regulations
• Switzerland to retain work permit quotas for EEA, UK and third-country nationals in 2025
• Switzerland publishes updated vacancy reporting requirements for 2025
• UK publishes Statement of Changes to the immigration rules

     Oceania

• Australia passes legislation to implement global and domestic minimum tax
• Australia's public country-by-country reporting law passes all stages of Parliament

      This week's EY publications

     Banking and Capital markets

• What to know about gaining access to U.S. Treasury central clearing
• How embedded payments can transform a utility into a growth driver

     Energy

• How GenAI could simplify rate case filings amid energy transition movement
• Why utilities should reimagine their Tax and Finance functions

     Insurance

• Reimagining risk: how AI is transforming commercial insurance

     Mergers and Acquisitions

• Navigating 2025 tax policy uncertainty in mergers and acquisitions

     Mining and metals

• Renaissance: defining the next era of metals and minerals

     Tax

• How a decade of transparency forever changed the tax world
• How to alleviate BEPS 2.0 Pillar Two data challenges
• Six steps to prepare for the operational impact of Pillar Two
• Six actions for tax teams before year-end 2024
• Treatment of US multinational IP transfers in a Pillar Two world

Additional resources

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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.