Tax planners need to be keenly aware of the impact of tax treaties as they consider structuring a firm's business in Latin America. For example, advisers are increasingly recommending the use of Europe for investments into Latin America, not only from a holding company perspective, but also from a financing and royalty stream perspective. Within Europe, the one jurisdiction that probably is the most attractive for treaty planning is Spain. Other jurisdictions include Netherlands, Luxembourg and possibly Denmark. To help firms navigate treaty planning, WorldTrade Executive has just published a new special report "Using Treaties and Holding Companies for Latin American Tax Planning". The report details planning opportunities for: Argentina, Brazil, The Caribbean, Chile, Colombia, Mexico, Venezuela. There are also detailed reports on the use of holding companies based in Europe and elsewhere and special situations such as technical assistance, royalty and service payments.
Table of Contents
Overview: 1) Tax Treaty Planning in Latin America; Argentina: 1) Tax Treaties of Argentina; Brazil: 1) Tax Treaties of Brazil; Caribbean: 1) Barbados and the U.S. Sign Second Protocol to the 1984 Income Tax Treaty; 2) The Income Tax Treaties of Barbados, Jamaica and the Republic of Trinidad and Tobago; Chile: 1) The Income Tax Treaties of Chile; 2) Status of the Chilean Tax Treaty Network; Colombia: 1) Colombia: Modifications to the Andean Pact Treaty; Mexico: 1) The Income Tax Treaties of Mexico; 2) Mexico Has Started Collecting a 25% Withholding Tax on Certain Payments by Mexican Companies to Foreigners; 3) The "New" Concept of Business Profits under the Mexican Income Tax Law and the Effect to Treaties for the Avoidance of Double Taxation; 4) New Commentaries to the OECD Model Convention; 5) Australia-Mexico Tax Treaty Enters into Force; Venezuela: 1) Tax Treaties of Venezuela; 2) Venezuela-Spain Double Taxation Treaty Published; 3) The Venezuela-Canada Double Tax Treaty Enters Into Force; Holding Companies: 1) The Use of Holding Companies for Investments into Latin America; 2) Mexico's New Controlled Foreign Corporation Tax Regime No Longer Applies Exclusively to Tax Haven Countries; 3) U.S. Multinationals Risk Losing Tax Deferral: "Grandfather Protection at Issue for S.A.'s in Certain Latin American Countries"; Technical Assistance, Royalty and Service Payments: 1) Clarifications Regarding Royalty and Service Payments Under the Brazil-Spain Tax Treaty; 2) Interpreting Technical Assistance Services Under Mexican Tax Law; 3) Taxation of Software Payments