| | This week's tax news from the Americas - Bermuda Parliament adopts Tax Credits Act 2025 and Corporate Income Tax Amendment (No. 2) Act 2025
On 11 December 2025, the Governor gave assent as the final step to enact the Tax Credits Act 2025 (Credits Act) and the Corporate Income Tax Amendment (No. 2) Act 2025 (Amendment Act), as passed earlier in the month by the Bermuda Parliament. These Acts implement measures released for public consultation in September 2025 and introduce refinements relevant to multinational enterprise groups operating in Bermuda. The Credits Act formalizes the substance-based tax credit, community development tax credit and utilities infrastructure tax credit, with several notable refinements from the consultation draft. The Amendment Act introduces targeted technical amendments to the Corporate Income Tax Act 2023, including integration with the new tax credit regime and additional administrative provisions.
- USTR outlines plan for USMCA review
US Trade Representative (USTR) Jamieson Greer briefed lawmakers on Capitol Hill regarding the Administration's current views of the operation of the US-Mexico-Canada Agreement (USMCA), issues between the three countries, and whether it will extend the terms of the Agreement as part of the July 1 Joint Review. In short, USTR described stakeholder views as being mostly supportive of the USMCA but that improvements are needed. USTR outlined a number of key issues that it believes must be addressed by Canada, by Mexico, and trilaterally before USTR will recommend to the President that the USMCA be extended for another 16-year term.
- Canada releases information on measures announced to protect domestic steel industry
On 12 December 2025, Canada’s Minister of Finance and National Revenue announced various measures to support the Canadian steel industry. These measures were first announced by Prime Minister Mark Carney on 26 November 2025. Effective 26 December 2025, Canada will further reduce the tariff-rate quota levels for certain imports of steel products from non-free trade agreement partners, as well as for certain imports from countries with which Canada has a free trade agreement (excluding Mexico and the United States). Canada will also impose a 25% global tariff on certain imported steel derivative products effective 26 December 2025.
- Canada tables bill with accelerated capital cost allowance and other immediate expensing measures
On 18 November 2025, Canada’s federal government tabled Bill C-15, Budget 2025 Implementation Act, No. 1, which included several measures related to accelerated capital cost allowance and other immediate expensing measures. The proposed measures, which were confirmed in the 2025 federal budget, reintroduce proposals initially included in the 2024 budget and the 2024 Fall Economic Statement.
- Brazilian tax authority issues guidance on new withholding tax on dividends paid to nonresidents
In a Q&A document published 16 December 2025, the Brazilian Federal Revenue clarified key points raised by the 26 November 2025 enactment of Law No. 15,270/2025, which introduced a 10% withholding tax on dividends paid to nonresident individuals and legal entities, effective 1 January 2026. The Q&A document addresses the applicable rate for tax-haven residents, exemptions for dividends approved through 31 December 2025 or paid to certain beneficiaries, rules for profit capitalization and operational aspects, such as payment deadlines.
- Argentina updates transfer pricing compliance obligations
On 16 December 2025, Argentina published, in the Official Gazette, General Resolution (ARCA) 5798/2025 amending General Resolutions (AFIP) 4717, 5010 and 5048 to align the minimum amounts required for compliance with the transfer pricing obligations with the provisions of Decree 767 of October 2025.
- Peru and United Kingdom have now both ratified double-tax treaty
On 10 December 2025, the United Kingdom ratified its double-tax treaty (DTT) with Peru. Peru had ratified the text on 20 November 2025. For the DTT to enter into force, both of the contracting states must notify one another through diplomatic channels. The DTT will enter into force 30 days after the last notification.
- USTR notice implements new trade framework between the United States, Switzerland and Liechtenstein
In a notice (USTR Notice) published in the Federal Register on 18 December 2025, the United States Department of Commerce and the Office of the US Trade Representative (USTR) implemented certain tariff-related elements of a trade framework between the United States, Switzerland and Liechtenstein. The USTR Notice modifies the Harmonized Tariff Schedule of the United States to apply, for products from Switzerland or Liechtenstein, the higher of either the US most-favored-nation (MFN) rate or a total rate of 15%. The 15% rate consists of the MFN duty plus a country-specific tariff under the International Emergency Economic Powers Act.
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| | About Americas Tax Roundup Published by NTD's Tax Technical Knowledge Services Group, Washington, D.C.
Jennifer Mannetta, writer and editor Distributed weekly to all Americas Tax personnel. | |
