Tax & Legal, KPMG Americas* webcast series

Thursday, July 27, 2023 – 11:00 a.m.–12:00 p.m. (US EDT)

On June 22, 2023, the US Senate approved the US‑Chile Double Tax Treaty (the Treaty), subject to two reservations.

The approval by the Senate paves the way for the United States to send its instrument of ratification to Chile. Chile completed its approval of the Treaty in 2015, but without the reservations. Chile would need to approve of the two reservations before the Treaty could come into force.

If the Treaty enters into force, it would be the first to come into effect between the United States and a Latin American country in more than 20 years, and it would be expected significantly to facilitate cross‑border investments between the United States and Chile, one of Latin America’s most important markets.

You are invited to join a panel of KPMG member firm partners for a session addressing the following topics that are of particular interest to US and Chilean investors as well as multinationals:

• Current status on the ratification of the Treaty between the United States and Chile
• Impact of the reservations adopted by the United States including as to Chile’s approval process
• Key provisions impacting US and Chilean investors and multinationals
• Practical examples of structuring options under the Treaty
• Expected impact in the region

Presenters will include Niren Saldanha, Tax Partner, KPMG US, and Latin America Deputy Tax Leader, Tax & Legal, KPMG Americas*; Quyen Huynh, International Tax principal, Washington National Tax practice, KPMG LLP (US); Javiera Suazo, Tax partner, International Tax, KPMG Chile; and Julio Castro, International Tax principal, KPMG LLP (US).

Thursday 17 November 2022 - 11:00 a.m.– 12:00 p.m. (U.S. EST)

In August 2022, the new Colombian government submitted to the Colombian Congress a first draft of a Tax Reform Bill, aimed at increasing tax revenue by billions of dollars. Although the generally applicable corporate tax rate is expected to remain the same, the Tax Reform Bill introduces several new revenue raising measures applicable to corporate taxpayers. Discussions on various provisions have been active and ongoing since the Bill was released, and taxpayers are scrambling to get their arms around the potential changes ahead of the proposed, January 1, 2023, effective date.

This session will cover the following topics of particular interest for foreign investors:

• Changes to the Colombian corporate income tax system, including a slate of new, industry specific surtaxes
• Changes to dividend withholding for resident and nonresident shareholders
• The introduction of a 15 percent minimum tax rule and a digital services tax
• Industry specific implications of the proposals.

Presenters include Niren Saldanha, Tax partner, KPMG LLP (U.S.) and Latin America deputy Tax leader, KPMG Americas Tax & Legal*; Kimberly Tan Majure, International Tax principal, Washington National Tax practice, KPMG LLP (U.S.); Ricardo Ruiz, Tax partner and head of Tax & Legal, KPMG Colombia; and Oscar Munevar, International Tax Director, KPMG Colombia.

Wednesday 14 September 2022 - 11:00 a.m.–12:00 p.m. (U.S. EDT)

The Chilean government recently submitted a significant tax reform bill to Congress, which would, among other things, substantially modify the current, integrated income tax system. These modifications are expected to have significant impact for foreign investors, particularly those resident in non-treaty jurisdictions.

Some of the changes are intended to enter into force between 2023 and 2025, and go into effect in 2026. However, significant discussion and debate is expected to take place in Congress before the bill can be passed into law. Hence, the result of the tax reform bill remains uncertain.

This session will cover the following topics of particular interest for foreign investors:

• Change from an imputation system to a dis-integrated one, and the potential impact on taxation of (nonresident) shareholders;
• Transition rules for foreign investors, and special implications for U.S. investors;
• Changes to the domestic corporate income tax rate; and requirements for rate reduction;
• Other changes that would affect cross-border investment, such as new Chilean restrictions on creditability of foreign income taxes, reduction in net operating loss absorption, modification of the domestic GAAR and rules related to taxpayer initiated transfer pricing adjustments, among others.

Presenters include Niren Saldanha, Tax partner, KPMG LLP (U.S.) and Latin America deputy Tax leader, KPMG Americas Tax & Legal*; Kimberly Tan Majure, International Tax principal, Washington National Tax practice, KPMG LLP (U.S.); Andrés Martínez, Tax partner, International Tax, KPMG Chile, and Javiera Suazo, Tax partner, International Tax, KPMG Chile.