Americas

Argentina, Brazil agree on key tax treaty changes

Francisco Lisboa Moreira of Castro Barros, São Paulo, and Sandra Diaz of BaseFirma, Buenos Aires, discuss key changes to the Brazil-Argentina tax treaty, agreed to July 21, noting that taxpayers from both countries may need to evaluate this new arrangement . . .

Americas

Brazil changes its position on tax treatment of cross-border payments for data centers

The Brazilian Revenue Service, in Declaratory Interpretative Act 07 (ADI 07/2014) released August 15, has modified its position concerning the tax treatment of amounts paid by a Brazilian residents to foreign legal entities for the provision of infrastructure for data processing and storage with remote access, deeming such payments to be payments for the provision of services, writes EY in an August 20 tax alert. For a discussion of the new guidance, see EY.