Germany: Federal Cabinet approves CbC reports exchange agreement with US
On 4 November 2022, the German Upper House of Parliament (Bundesrat) approves bill No. 567/22 for consideration to ratify the competent authority agreement (CAA) on the exchange of country-by-country (CbC) reports with the US. The competent
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Cyprus: Clarification Bilateral Agreement for exchange of CbC between Cyprus and the USA
On 13 October 2022, the Cyprus tax authority informed all legal entries and their representatives that the bilateral Competent Authority Arrangement (CAA) for the exchange of Country-by-Country (CbC Reports) between Cyprus and the United States of
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Mexico: Senate approves BEPS MLI
On 12 October 2022, the Mexican Senate approved the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Mexico signed the MLI on 7 June 2017. Mexico must now deposit its ratification
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Colombia: Congress approved Tax Reform Bill in the first debate
On 6 October 2022, the Colombian Congress approved Tax Reform Bill in the first debate. The Bill was presented to Congress on 8 August 2022. After the final approval of the Bill, the changes will become effective as of 1 January 2023. The main tax
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Peru: SUNAT updates the list of high-risk tax planning schemes regarding GAAR
On 11 October 2022, the Peruvian Tax Administration (SUNAT) published second version of the list of high-risk tax planning schemes regarding the General Anti-Avoidance Rule (GAAR). The updated list contains the following thirteen tax planning
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Puerto Rico extends tax returns and payment deadline due to Hurricane Fiona
On 27 September 2022, the Puerto Rico Treasury Department (PRTD) issued Administrative Determination No. 22-08 extending the due date for income tax returns and tax payments due to Hurricane Fiona. The PRTD extends the tax returns deadline until
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Turkey approves effective date on CAA regarding CbC exchange arrangement with US
On 13 September 2022, the Turkish Revenue Administration issued Presidential Decision No. 6033 in the Official Gazette, through which Turkey has approved the effective date of the Competent Authority Agreement (CAA) to exchange country-by-country
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Dominican Republic: DGII Publishes general standard rule on MAP
On 30 August 2022, the Dominican Tax Authorities (DGII) issued a new general standard rule on Mutual Agreement Procedures (MAP) for Dispute Resolution under the country's tax treaties. The general rules introduced details for submitting MAP
See MorePeru submits a draft bill to Congress to ratify BEPS MLI
On 8 September 2022, a draft bill was submitted to the Peruvian Congress for the ratification of the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). Peru signed the convention on 27
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Argentina: MoE publishes new late tax payment and refund interest rates
On 23 August 2022, the Argentine Ministry of Economy published Resolution 559/2022, which provides new rates for late tax payments and reimbursement interest. The latest repeals Resolution 598/2019, which established rules for setting interest rates
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Brazil and the UK Begin Negotiations for a Double Tax Agreement
Following the completion of exploratory talks, the UK and Brazil are to hold a first round of negotiations on a double taxation agreement from 12 to 16 September 2022. Brazil began accession discussions with the OECD on 25 January 2022 and has
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US: Sixth Circuit affirms taxpayer not liable for penalty upon cancellation of APAs
On 25 August 2022, the U.S. Court of Appeals for the Sixth Circuit affirmed in part and reversed in part a decision of the U.S. tax court regarding the transfer pricing case of Eaton Corp. v. Commissioner. Facts of the case Eaton Corporation
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El Salvador: Legislative Assembly adopts tax amnesty program
On 24 August 2022, the Legislative Assembly of El Salvador approved tax amnesty program that allows taxpayers voluntarily come forward, accurately declare their income and pay any undeclared or underreported taxes. The El Salvador tax authorities
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US: IRS provides broad-based penalty relief for certain 2019 and 2020 returns
To help struggling taxpayers affected by the COVID-19 pandemic, on 24 August 2022, the Internal Revenue Service issued Notice 2022-36, which provides penalty relief to most people and businesses who file certain 2019 or 2020 returns late. The relief
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Paraguay updates list of low-tax Jurisdictions
On 24 August 2022, the Paraguayan tax authority (SET) issued General Resolution No. 118/2022, concerning the Transfer Pricing Technical Study (ETPT) and a list of low-tax jurisdictions. The amended list of low-tax jurisdictions are
See MoreUS: Tax court issues an opinion regarding transfer pricing method
On 18 August 2022, the U.S. Tax Court issued an opinion on the transfer pricing case of Medtronic, Inc. v. Commissioner, T.C. Memo 2022-85. Facts of the case Medtronic US is the parent company of a global medical device company that
See MoreUS Inflation Reduction Act includes 15% corporate minimum tax on book income
On 16 August 2022, the President of the United States (US), Joe Biden, signed the Inflation Reduction Act (the Act) into law providing a 15% corporate alternative minimum tax (CAMT) based on book income. The Corporate Alternative Minimum Tax (CAMT)
See MoreArgentina issues resolution introducing exceptional tax prepayment obligation
On 16 August 2022, Argentine tax authority (AFIP) published General Resolution No. 5248/2022, requiring a one-time tax payment for certain large companies that benefitted from deducting losses due to the coronavirus pandemic and ongoing
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