El Salvador: DGII updates transfer pricing information return and guidelines
On 1 October 2018, the Tax Authority (General Office of Internal Revenue ) updated the new version of the “Report on Operations with Related Parties (Form F-982v4),” whose method of filing is now changed from manual filing to online filing and
See MorePeru introduces GAAR, new thin capitalization rule, definition of PE, and Other Changes
On 13 September 2018, the Peruvian government has published Legislative Decree No. 1422 and Legislative Decree No. 1424, which include measures for the implementation of the General Anti-Avoidance Rule (GAAR), new thin capitalization and interest
See MoreSweden:The Administrative Court approves the position of the tax administration on interest on withholding tax refunds
Recently, the Swedish Tax Agency issued a notice concerning a ruling by the Supreme Administrative Court stating that recipients of dividends on which taxes have been levied are entitled to interest if the tax is later refunded. The notice notes
See MoreRussia: Central Bank hikes late payment interest penalty
On 14 September 2018, Russia’s central bank raised the late tax payment interest rate from 7.25% to 7.5% and said it would not make any foreign currency purchases until the end of the year, citing the risk of higher inflation and rouble
See MoreSweden: Tax Authority releases updated guidance on hard-to-value intangibles
On 13 September 2018, the Swedish tax authority published an update of transfer prices guidance on intangible assets consistent with OECD's difficult-to-measure intangible assets (HTVI) guidance. The OECD HTVI Guidance offers tax authorities with a
See MoreBrazil: Administrative Council of Tax Appeals approves validity of resale price method (PRL 60)
The Administrative Council of Tax Appeals (CARF) issued binding decision 115 (Súmula no. 115) on 11 September 2018. The new decision approving that, the calculation method of the ' 60% Profit Price Less Profit Method (PRL 60)' provided for in
See MoreSweden: Government announces a legislative proposal to amend the CFC rules
On 4 September 2018, The Swedish government published a legislative proposal to amend the country's controlled foreign company (CFC) rules to comply with the EU Anti-Tax Avoidance Directive (ATAD1). Under the CFC rules, income of foreign entities
See MoreWorld Tax Brief: September 2018
Chile Business income taxation: On 21 August 2018, the Chilean president announced that a bill on tax reform would be submitted to Congress. The tax reform laws would propose a single integrated corporate tax system that would eliminate the
See MoreMexico: Tax authority updates the transfer pricing adjustment rules
Recently, the Mexican tax authorities issued the Second Resolution of modifications to the 2018 Miscellaneous Tax Resolution (MTR) in which the rules regarding transfer pricing adjustments were amended and certain additional provisions were
See MoreIndia: CBDT publishes second APA annual report
The Central Board of Direct Tax (CBDT) released the second annual report (2017-18) of its advance pricing agreement (APA) programme on 31 August 2018. The report introduced a report card of the performance of the programme along with qualitative and
See MoreBrazil: RFB clarifies Transfer pricing rules on import of products
On 30 august 2018, the Department of Federal Revenue of Brazil (RFB) published a ‘Private Ruling 95/2018’ in the Official Gazette which clarifies the calculation of price parameter on import of steel product for resale. Under this Private Ruling
See MoreSweden: Tax Agency updates Transfer Pricing Guidance on Profit Splits method
On 29 August 2018, the Swedish Tax Agency (Skatteverket) has updated its transfer pricing guidance to incorporate the OECD guidance on the application of the transactional profit split method, which was revised as part of the work for BEPS Action
See MoreColombia updates late payment interest rate for September 2018
According to an Administrative Regulation 1112 of 2018, the effective monthly interest rate for late payment of taxes has been set at 27.72% and valid from 1 to 30 September
See MoreEgypt reduces late payment interest, penalties and additional taxes if taxes are settled
On 15 August 2018, the Egyptian Government has issued new Law no. 174 of 2018 (the Law) that reduces late payment interest and penalties by a certain percentage based on the payment day of the taxes due. The law introduces 90% reduction on interest
See MoreGermany: Ministry of Finance confirms exchange of CbC Reports with the U.S. for 2016
On 16 August 2018, The German Ministry of Finance published a letter on the spontaneous exchange of CbC reports between Germany and the United States (US) concerning reporting fiscal year 2016. This follows a joint statement between Germany and the
See MoreDominican Republic: DGI publishes guide on simplified tax procedure
On 19 June 2018, the Directorate General of Internal Revenue (DGII) issued Guide No. 24 for individuals and legal entities wishing to qualify for the simplified tax procedure (PST). The Simplified Tax Procedure (PST) is a special regime that
See MoreRussia modifies transfer pricing rules
On 3 August 2018, the President of the Russian Federation signed Law No. 302-FZ About changes to Part One and Two of the Tax Code of the Russian Federation" Once the new law enters into force, only transactions between Russian companies that apply
See MorePeru: Ministry of Finance publishes Legislative Decree on deductions for royalties and service fees
Peru's Ministry of Finance published Legislative Decree No. 1369 on 2 August 2018 regarding amendments in relation to deductions for royalties and service fees paid to non-residents. The amendment provides that royalties and service fees paid to
See More