Opportunity in Latin America

Transcription

1 Opportnity in Latin America EY takes a detailed look at the opportnities and challenges presented by Soth America s diverse and complex tax landscape. Web: Brazil, Brasilia, view of the city, chrch The Latin America insrance otlook for 2015 is generally favorable, with high single-digit premim growth predicted. Althogh economic growth has slowed in the largest markets of Brazil and Mexico, more robst conditions in other regions are driving premims. Overall demand for insrance is rising becase of shrinking poverty and nemployment, a growing poplation and rising concern over natral disaster risks. Key challenges inclde the need to develop more efficient distribtion systems to increase market penetration and inflation risk. Althogh annal inflation rates in Chile, Per and Colombia have averaged between 2% and 3%, significantly higher rates exist in Argentina and Venezela. In Argentina, the contry s battles with creditors and a strong governmental hand in foreign exchange controls have destabilized its crrency. In Mexico, conversely, the government s stability is fostering reforms to modernize insrance and other sectors. Or report explores market conditions and tax incentives for investors in Latin America on a contryby-contry basis, focsing on the largest markets of Brazil, Mexico, Chile, Argentina, Colombia and Per. Venezela is exclded from this year s report, as it has become less attractive to global insrers. From a tax perspective: Brazil imposes the highest income tax in the region, with insrer profits taxed at 40%. Poplar prodcts inclde health and term life insrance, atomobile and property insrance. Tax incentives for retirement accmlation plans are increasingly poplar. Mexico s income tax strctre and tax incentives to promote retirement savings are boosting premim growth. Third-party atomobile liability coverage is mandatory in several cities, improving the atomobile insrance premim volme. In Chile, where atomobile insrance is complsory, intense price competition prevails. Provisional life and retirement prodcts are part of the social secrity system and approximately half of all insrers are sbsidiaries of international firms. An open market has stabilized competition. In Argentina, the nationalization of private pension fnds has redced the size of the life and annity market and lowered the nmber of insrers. High income taxes are imposed, with profits taxed at 35% and a 10% dividend withholding tax. Colombian investments in infrastrctre are encoraging higher demand for garanty bonds. Dividends paid to nonresident insrers are not sbject to tax if the dividends are paid ot of profits taxed at the corporate level. If not taxed at the corporate level, the dividends are sbject to income tax at a 33% withholding rate (the law enacted in December 2014 is not clear and gidance from the Government is expected early 2015, however, it is likely that Colombian withholding agents wold apply the highest rates, e.g. 39% for 2015). In Per, rapid economic growth is giding changes in consmer protection, tax legislation and insrance reglation. Growth is forecast at 6% in 2015, compared with 1.5% in Brazil and 1.1% in Mexico. Many foreign companies now consider Per safe and desirable for investment. Latin America Tax landscape for Latin American insrers The market in general Strong economic growth and reglatory reforms in Latin America have attracted global insrers, reinsrers and insrance brokers that are bilding positions regionally throgh mergers and acqisitions. Latin American-based insrers also have increased their size and market reach throgh cross-regional expansion, and are enhancing their capabilities in prodct development and risk management. Solvency II-type insrance capital management reglations shold spr frther indstry consolidation and increase risk management sophistication. Low market penetration rates create significant opportnities as the region s economic expansion contines. Long-standing isses like wealth disparity, insfficient tax incentives for retirement prodcts and a poor nderstanding of the vale of insrance are being corrected. Different economic conditions prevail: Argentina is experiencing high inflation, tight reglation and flctating economic conditions; both Argentina and Venezela have strict control of foreign exchange, generally disallowing companies from paying 20 Acqisition International - Febrary 2015

2 2015 Tax Awards dividends or inter-company services and royalties otside of the contry, and may limit the dedctibility of certain payments; and doble-digit declines in premims in low-hazard markets in Brazil are affecting margins. Nevertheless, insrance remains a fast-growing indstry across Latin America, demonstrating resilience in premims and tolerance for expansion. Tax systems for insrers A key concern is the region s vale added tax (VAT) system. VAT paid on the local prchase or importation of goods or services constittes an inpt VAT that typically shold be credited against the otpt VAT generated on the taxable sale of goods or services. The VAT calclation methodology is complex and sally reslts in some level of irrecoverable VAT, reslting in an nexpected cost when entering a market. Some insrance prodct sales are exempt from VAT, sch as life insrance and workers compensation in Argentina, life and pension insrance in Mexico, and contracts related to international trade in Chile. VAT incrred on the local prchase of goods or services becomes an irrecoverable cost for an insrance company in these contries, althogh it is dedctible for corporate income tax prposes. Contry Tax rate Net operating loss (NOL) Withholding dividends Withholding interest Withholding Treaty network VAT IPT Argentina 35% 5 years 10% % / 35% 3.5% Limited 0% / 21% Brazil 40% Unlimited 2 0% 15% / 25% 1.20% / 2% Limited 2% / 5% Chile 3 21% 4 Unlimited 35% 5 4% / 35% 2% Extensive 0% / 19% Colombia 39% 6 Unlimited 0% / 20% / 33% 0% / 14% / 33% 0% Limited 0% / 16% Costa Rica 30% 3 years/5 years 15% 15% 5.5% Limited 0% / 13% N/A Per 8 28% 4 years/nlimited 7 6.8% 4.99% / 30% 2.1% Limited 0% / 18% Mexico 30% 10 years 10% 4.9% / 40% 2% / 40% Extensive 0% / 16% Panama 25% 5 years 10% 12.5% N/A Limited 0% / 7% 7% 1 If the amont of a dividend distribtion or a profit remittance exceeds the after-tax accmlated taxable income of the payer, a separate final withholding tax of 35% may be imposed on the excess, regardless of the application of the general 10% withholding tax. 2 Can only offset p to 30% of the company s taxable income. 3 Tax reform has been enacted, as noted in the Chilean section. 4 Increase in corporate income tax: FY %, FY %, FY % and FY % or 25.5% for distribtion system (increased to 27% for FY2018 for distribtion system with only 65% creditable against dividend withholding tax). Under the attribtion regime, the total tax cost shold be 35% and, nder the distribtion regime, the total tax cost may be increased p to 44.45% in the year of the actal dividend distribtion, nless the shareholder is a resident in a tax treaty contry. 5 Thirty-five percent mins corporate income tax credits, as discssed in the Chilean section. 6 CREE (Impesto sobre la Renta para la Eqidad CREE by its Spanish acronym, is a new income tax to fnd the National Learning Service (SENA) and Family Welfare Instittion (ICBF)) tax srcharge from 2015 to 2018 on profits exceeding a relatively low threshold, as follows: %, %, % and %. The basic CREE tax rate is kept at 9% (the redction of the rate to 8% from 2016 was repealed). Ths, considering a 25% corporate income tax rate, the 9% CREE tax and the proposed srcharges above, the total tax rate for Colombia shold be approximately 39% in FY2015, 40% in FY2016, 42% in FY2017 and 43% in FY Sbject to an annal dedctible limit eqal to 50% of the taxable income each year. 8 Tax rate and dividend withholding rates are applicable for FY2015 and FY2016. Tax reform has been enacted, as noted in the Pervian section. Acqisition International - Febrary

3 In Brazil, insrers are sbject to taxes on gross revenes from the contry s Social Integration Program (PIS) and Contribtion for the Financing of Social Secrity (COFINS). These are paid on a cmlative basis at a combined rate of 4.65% and are not a recoverable cost. Brazil also has a state VAT (ICMS, by its Portgese acronym) and a federal VAT (IPI, by its Portgese acronym), bt these taxes do not apply to the sale of insrance prodcts.* *Other taxes inclde the ISS (Mnicipal Service Tax) tax on services and certain taxes on gross revene and prodct-level taxes, sch as the financial transactions tax or IOF. Property and casalty insrance, atomobile insrance, professional liability, and environmental and finance soltions are generally sbject to VAT in Latin America, so any VAT paid shold be flly recoverable for the local insrance company. In addition to the VAT, some Latin American contries impose additional layers of indirect taxes that shold be careflly reviewed by local insrers (e.g., gross revene taxes, taxes on financial transactions, net worth taxes, and stamp taxes, among others). Potential exit strategies are another tax consideration, as many Latin American contries impose a capital gains tax on the sale of domestic company shares. Also, tax administration is inconsistent in its adversarial or cooperative position with taxpayers. The transparency of administrative, legislative and jdicial matters is also a concern. Brazil Brazil is Latin America s largest insrance market, generating 48.4% of the total premims in Brazil s insrance indstry achieved 18.8% premim growth and a market penetration rate of 3% to 4% from 2009 to Nevertheless, a doble-digit premim decline in low-hazard markets is compelling insrers to seek more profitable opportnities. Life insrance is primarily term life coverage, creating opportnities to market niversal, variable and whole life prodcts. Distribtion channels are few bt well established. Since insrers are not allowed to distribte prodcts directly, life and retirement prodcts are sold primarily throgh bancassrance. General insrance is commonly sold by independent brokers, and has traditionally centered on atomobile and property, althogh specialty lines and micro-insrance prodcts are growing. Competition is largely based on price. Intercompany reinsrance restrictions are an nwelcome srprise to international insrers and reinsrers. Prospects are boyed by the large infrastrctre projects in preparation for the 2016 Smmer Olympics. High tax brden Brazil imposes the highest income taxes in Latin America, taxing insrer profits at 40%. Monthly trnover taxes (PIS and COFINS) are imposed at a 4.65% rate on operational gross revene. For remittances on the importation of services, PIS and COFINS are de at a combined rate of 9.25%. The PIS and COFINS rate on ceded premims in reinsrance contracts is 1.39% of the total amont being remitted (15% withholding tax rate on a basis eqal to 9.25% of the premim). Tax losses can be carried forward indefinitely, bt annal sage is limited to 30% of income. There is no withholding tax on dividends, bt the withholding tax on interest is 15%, generally increasing to 25% if interest is paid to a creditor in a contry with a tax rate lower than 17%. The withholding rate on ceded premims is 1.20% to 2%. Brazil s limited income tax treaty network is a brden for insrers. De to the high income tax rate, insrers generally maintain a minimal amont of capital and distribte profits qickly, rnning conter to rating agency dictates encoraging capital to be maintained in Brazil. Acqiring capital throgh debt can be achieved, bt is sbject to withholding tax. Markets are limited insofar as where debt originates and reinsrance is ceded. Withholding tax is recaptred only if imposed on cash flows received in contries with a foreign tax credit regime permitting recovery of taxes. Acqiring capital throgh external reinsrance can be accomplished, bt the restrictions on internal reinsrance limit the se of traditional capital management tools. Brazil s approach to transfer pricing cases an added tax brden for local insrers and reinsrers. Since bancassrance is the dominant channel, many life insrers enter joint ventres with Brazilian banks. These arrangements can be beneficial with respect tospeed-to-market; however, they frther limit available tax planning to those areas that do not skew the economics of a joint ventre arrangement. Additionally, the annal limit on the se of NOLs (net operating losses) increases the after-tax costs of growth. Brazil offers interesting tax strategies for local acqisitions (e.g., treatment of goodwill amortization) and allows payment of interest on net eqity (INE). Brazilian companies are allowed to pay or declare INE at a rate established by the Brazilian Central Bank (the greater of 50% of retained earnings or 50% of the crrent year s earnings). This generally reslts in a tax arbitrage of 25% (40% combined corporate income tax rate mins 15% withholding tax). Mexico Mexico is Latin America s second largest market. The stability of Mexico s economy, tax incentives promoting retirement savings and low market penetration rate bode well for insrers. New insrance reglations are driving market consolidation and specialty and consmer prodct lines growth. High demand for life insrance is reflected in individal life premims, p 23% in 2013, following a 19% increase in Recent reforms in the oil and gas and electric energy sectors may generate additional insrance opportnities. The Angel of Independence (Victory colmn) over Paseo de la Reforma in downtown Mexico City, Mexico Premims grew approximately 8.1% in 2014, yet less than 10% of homes are insred for fire and theft, and less than 30% of cars are insred. Insrance prodcts are distribted primarily throgh independent brokers, direct marketing and bancassrance. Open market conditions prevail and a high nmber of international companies are present. Premim volme is largely generated by third-party atomobile liability insrance, althogh price competition cases high trnover. Other prodcts inclde life insrance and pension prodcts for individals and grops. Renewable term and whole life insrance are common forms of individal coverage. Grop life and accident and spplemental health policies are written by general and life insrers. Despite the open market, foreign reinsrers mst register with the General Registry of Foreign Reinsrers and have minimm ratings of B+ (A.M. Best), BBB- (Fitch), Baa3 (Moody s) or BBB- (Standard & Poor s). The national reglator, the Mexican Insrance and Bonds Commission (CNSF), 22 Acqisition International - Febrary 2015

4 2015 Tax Awards closely monitors the reinsrance indstry, reqiring a separate annal bsiness plan for each line. Solvency II-type reglation Insrance reglation is evolving toward risk-based capital approaches to solvency assessment. Mexico has set a 2015 compliance date for a Solvency II-style framework. While not a fll implementation of Solvency II, the reglation will have a significant impact on Mexican insrers. Mexico s corporate income tax rate is 30%. A dividend withholding tax of 10% is imposed, althogh certain tax treaties may redce or eliminate it. The federal government has the sole athority to tax, simplifying administration. Tax athorities have increased adit activities of taxpayer disclosres, particlarly involving transfer pricing. In certain cases, taxpayers mst demonstrate a transaction was not engineered exclsively for tax prposes. If deemed the case, athorities can re-characterize the transaction. Mexican Base Erosion and Profit Shifting (BEPS) rles restrict the dedctibility of certain interest, royalties and technical assistance in sitations where: 1. Payment is made to a foreign entity that is fiscally transparent, nless the shareholders or partners are sbject to tax on the income of this entity and the payment is made at arm s length View of Santiago de Chile with Los Andes montain range in the back 2. Payment is not deemed to exist for tax prposes in the contry or territory where the entity resides 3. The foreign entity does not recognize the payment as taxable income Capital management Tax losses can be carried forward 10 years. A 10% withholding tax on dividends is imposed, as is a withholding tax on interest that ranges from 4.9% to 40%, depending on the natre and jrisdiction of the creditor. The withholding tax on ceded premims is 2%, rising to 40% if ceded to a low-tax contry. Mexico has the most extensive treaty network of Latin American contries, inclding agreements with Per, Colombia and Hong Kong. It recently expanded its agreement with Barbados, and signed a Tax Information Exchange Agreement with Bermda. Renegotiated treaties with the Netherlands and Switzerland are less generos than preceding agreements. Income tax compares well to major insrance jrisdictions, making the cost of maintaining capital reasonable and diminishing the incentive to distribte profits qickly. Shold Solvency II-type reglation reqire insrers to increase capital, larger pools may be sbject to a higher contry tax rate. Spplying capital via debt may be feasible if certain featres of Solvency II-type reglation are adopted, bt this wold reqire reglators to adjst their crrent stance regarding the se of debt. New reglations and the insrance market s expected growth and low penetration rate will compel frther indstry consolidation, joint ventres, crossborder alliances and the need for additional capital. Chile The steady rate of growth in insrance premims in Chile, the region s third largest market, has slowed de to the impact of the global financial crisis on atomobile sales and retirement savings. Penetration rates are ahead of other regions. Life insrance is sold primarily throgh direct sales and independent agents, whereas brokers are the predominant means of distribting property and casalty prodcts. Bancassrance and mass marketing throgh spermarket chains are growing. Intense price competition prevails in complsory atomobile insrance, which generates the majority of general insrance premims. Life and accident insrance are available for both individals and grops. Individal prodcts inclde renewable term, whole life and pensions. Grop life is generally available on a renewable-term basis. Provisional life and retirement prodcts are part of the national social secrity system. Workers in local pension fnds mandatorily pay for grop life and disability coverage. The reinsrance market is open. Acqisition International - Febrary

5 Reglation is moving toward risk-based capital reqirements and Solvency II, bt limited availability of insrance talent and data analytics will slow these developments. Reglators affirm their intent to reward insrers with strong risk management practices by reflecting this in their capital reqirements. The withholding tax on dividends is 35%, with an offsetting credit for income tax paid on distribted profits. The withholding tax on interest ranges from 4% to 35%, and on ceded premims is 2% when paid to a non-treaty contry. While Chile s treaty network is not as extensive as Mexico s, it contines to grow. Increase in corporate tax Tax reform increased the corporate tax rate to 22.5% for FY2015 and 24% for FY2016. Two taxation regimes will be enacted in 2017 as follows: 1. Attribtion CIT rate of 25% and deemed attribtion of profits with total tax cost of 35% on an accral basis. 2. Distribtion CIT rate of 25.5% for FY17 and 27% for FY18; pon actal distribtions, only 65% of the CIT paid wold be creditable against the 35% dividend tax cost (reslting in an effective rate of 44.45% in the year of actal dividend distribtion nless the shareholder is resident in the tax treaty contry). This limited CIT is applied throgh a refnd system. Previosly, Chile s income tax rate was one of the lowest in the region. New reglations confirm the right to offset existing tax losses against ftre profits, and to obtain a refnd for losses offset with profits distribted from other Chilean companies. Other significant tax changes inclde: The potential to distribte the accmlated taxed profits at a 32% dividend withholding tax rate with a credit for corporate income taxes paid dring FY 2015 only. Introdction of controlled foreign corporation (CFC) rles and anti-avoidance reglations. Transfer pricing assessments sbject to a 40% penalty tax rate. Increase in the stamp tax maximm rate from 0.4% to 0.8%. VAT changes on real estate transactions. Changes in the dedctibility of interest expense, capital gains tax, nondedctible expenses, goodwill amortization and the carryforward process. Elimination of the carryback of losses. As a reslt of these measres, internal reinsrance can be sed more easily and the 2% premim withholding tax can be minimized if the reinsrer is resident in a tax treaty contry. Unlimited loss carryforwards help make certain of the evental recovery of losses sally attribted to start-p operations. Argentina Insrance premims in Argentina, the forth largest market in the region, have steadily increased. While property/casalty insrance premims are growing, life and annity prodcts are expected to experience flat growth in the short-to-medim term. Insrance is distribted primarily by independent agents and brokerage firms, which accont for approximately 75% of the total premims. Other channels inclde bancassrance and direct sales. Insrers are likely to improve traditional channels and be catios abot alternative channel development. High policyholder trnover, especially in atomobile insrance, typically compels insrers to redce prices and increase commissions, which has a negative impact on nderwriting profitability. The nationalization of private pension fnds and Argentina s general sovereign risk have altered the insrance indstry s strctre, redcing the size of the life and annity market. Argentina s insrance Benos Aires Cityscape, Capital City of Argentina, Perto Madero Neighborhood reglator, the National Insrance Sperintendency (SSN), has pdated reserve standards and is establishing solvency reqirements and improved governance and internal controls. Reinsrance mst be placed with an Argentinean reinsrer. Local insrers are prohibited from making investments abroad and mst maintain minimm investments in prodctive initiatives. High income tax brden Profits are taxed at a very high 35%. Tax losses cannot be carried back and have only a five-year carryforward period, with no adjstment for inflation. There is a 10% withholding tax on dividends, and an additional 35% withholding if dividends are paid in excess of the accmlated pool of taxable profits. The withholding tax on interest ranges from 15.05% to 35%, and is 3.5% on ceded premims when paid to a non-treaty contry. Argentina s treaty network is not extensive and is with primarily Eropean contries. Strict foreign exchange controls make it difficlt to obtain approval from the Central Bank to allow resident entities to pay dividends, intercompany services and royalties otside of the contry. This may limit the dedctibility of certain payments. Transfer pricing is generally within OECD principles. The limited NOL carryforward period provides little time to tilize start-p or catastrophe losses, a concern considering low market penetration. In evalating the local insrance market, insrers shold consider the new reglations, restrictions on acqiring foreign crrency, relative high inflation, and recent crrency devalation and technical defalt. Colombia Colombia s growing economic stability and enhanced secrity are encoraging higher inflows of foreign investment, growing demand for exports and more favorable terms of trade with other contries in Latin America. The government is focsed on decreasing bdgets and pblic debt. Premim growth in 2013 was 8%, and penetration remains low at 2.5% of the GDP. Atomobile insrance represents 25% of the market, followed by complsory personal atomobile accident protection and fire and earthqake insrance. The largest personal and life insrance line is grop life, followed by private health insrance. Individal life insrance is not as developed as personal accident liability. Income tax brden Recent tax changes inclde: A new CREE income tax srcharge on profits exceeding a relatively low threshold 5% in 2015, 6% in 2016, 8% in 2017 and 9% in Considering a 25% corporate income tax rate, the 9% basic CREE tax rate pls the srcharges wold reslt in a total tax rate of 39% in FY2015, 40% in FY2016, 42% in FY2017 and 43% in FY2018. Reinstatement of the eqity tax from 2015 to 2017 at the applicable rate in the highest bracket of 1.15% for 2015, 1% for 2016 and 0.40% for Acqisition International - Febrary 2015

6 2015 Tax Awards Interest paid or accred by Colombian residents to foreign entities on loans with a term eqaling or exceeding one year is sbject to a 14% withholding tax; otherwise, the applicable rate is 33%. Colombia does not have a withholding tax on ceded premims. The Colombian treaty network is not extensive. The contry has a mltilateral tax treaty with Bolivia, Ecador and Per, and doble-tax treaties in effect with Canada, Chile, Mexico, Spain, Switzerland, India and Soth Korea based on the OECD model convention. Foreign investment Colombia permits complete foreign ownership of insrance sbsidiaries. A company grop mst have a commercial presence to sell policies other than international travel or reinsrance. Foreign companies are acqiring local companies to increase their market penetration. Colombia contines to engineer free trade agreements in the world s major markets. The government also is addressing catastrophe risk throgh a vlnerability redction program for schools and hospitals, in recognition that a 1-in- 250-year earthqake cold case more than US$35 billion in losses. Per The growing economy in Per and its efforts to develop its financial system and insrance indstry are attracting increased attention from foreign insrers and reinsrers. Per has enacted reglations as part of a national strategy designed to spr growth, and has streamlined its insrance system. The Sperintendency of Bank and Insrance (SBS) reglates insrance, reinsrance and financial entities and pension fnds. Qalified nonadmitted reinsrers (NARs) can write reinsrance, and resident entities are permitted to contract insrance or reinsrance policies from NARs. Foreign insrers can act as reinsrers for a domestic insrer, assming a BBB credit rating or by registering with the SBS and complying with its reqirements. Foreign investors may establish an insrance company in Per nder the form of a corporation and designate an intermediary like an insrance or reinsrance broker. They can determine the terms and conditions of insrance in their policies, inclding fees and commissions. Complsory insrance covers atomobile for personal injries, life and health insrance for employees of high-risk activities, coverage to transport hazardos materials and aviation liability. Per s penetration rate is estimated at 1% to 2%. Independent agents and brokers are the primary distribtors. Income tax brden Profits are taxed at 28%. Capital gains by nonresident entities are sbject to a 5% income tax if transfer is made in the Pervian stock exchange (otherwise, the rate is 30%). Tax losses cannot be carried back. To obtain relief for losses, insrers can select either a for-year carryforward period or a carryforward indefinitely sbject to an annal dedctible limit eqal to 50% of the annal taxable income. A 6.8% withholding tax for FY2015 and FY2016 on dividends is imposed on profits distribted to nonresident entities and individals. Withholding on interest paid to nonresidents is 30%. For interest paid to nrelated foreign lenders, the rate is 4.99% (if conditions are met). The withholding tax on ceded premims is 2.1%. Per has signed agreements to avoid doble taxation with Chile, Canada, Brazil, Spain, Mexico, Switzerland, Soth Korea, Portgal and the contries of the Andean commnity. Skyscrapers in downtown Bogota, Colombia Acqisition International - Febrary

7 Principal tax reform approved incldes: A redction in the corporate income tax rate from 30% to: Fiscal year Tax rate % % % An increase in the dividends tax rate from 4.1% to: Profits earned from Tax rate % % % Main exemptions related to the insrance indstry Life insrers and individals are exempt from income tax in certain sitations. These inclde: 1. Income that is derived from assets linked to technical reserves for payment of retirement, disability and srvivor pensions within the private pension fnd administration system. 2. Pervian individals are exempt with regard to the allowances derived from life or health insrance contracts. 3. Individals are also exempt from income tax when the income is derived from endowment insrance contracts and life insrance contracts. Conclsion Latin American markets mst balance competing interests and tax incentives to attract foreign investments from insrers and reinsrers. The gradal shift to IFRS and Solvency II will affect how these companies invest and the diversity of the risk they assme. As contries adjst their tax systems to manage their expected growth, insrers mst remain flexible in their growth plans. The views and opinions expressed in this article are those of the athors and do not necessarily reflect those of Ernst & Yong LLP. Contacts Latin America Michael Shields Ernst & Yong LLP michael.shields02@ey.com Pablo Wejcman Ernst & Yong LLP pablo.wejcman@ey.com James Littlewood Ernst & Yong LLP james.littlewood@ey.com Alejandro Rodrigez Ernst & Yong LLP alejandro.rodrigez@ey.com Local contry contacts Argentina Jorge Lapenta Pistrelli, Henry Martin y Asociados S.R.L jorge.lapenta@ar.ey.com Brazil Karina Emanele Maranhao Ernst & Yong Ltda karina.emanele@br.ey.com Marcs Segnini Ernst & Yong Ltda marcs.segnini@br.ey.com Mexico Oscar Ortiz Molina Mancera S.C oscar.ortiz@mx.ey.com Allen Saracho Carrillo Mancera S.C allen.saracho@mx.ey.com Colombia Ricardo Riz Ernst & Yong Ltda ricardo.riz@co.ey.com Chile Fernando Leigh Cort Ernst & Yong Servicios profesionales de Aditoria y Asesorias Limitada fernando.leigh@cl.ey.com Per Roberto Cores Ernst & Yong Asesores Sociedad Civil de Responsabilidad Limitada roberto.cores@pe.ey.com Central America Rafael Sayages Argello Ernst & Yong S.A rafael.sayages@cr.ey.com Jan Chavarria Pozelo Ernst & Yong S.A jan-carlos.chavarria@cr.ey.com Antonio Riz Rojas Ernst & Yong S.A antonio.riz@cr.ey.com Lima, Per: Panoramic view of the main sqare of the city 26 Acqisition International - Febrary 2015