Chile: Avery Dennison wins Chile transfer pricing dispute
On 31 March 2021, the Tax Tribunal issued its decision in one case of: Chile v Avery Dennison Chile S.A. , relating to the appropriateness of the inter-company loan interest rates of Avery Dennis and the price of the goods sold to the company by
See MoreArgentina: AFIP extends suspension of prosecution proceedings for tax collection again
In response to corona virus pandemic, on 26 March 2021, the Federal Public Revenue Administration (AFIP) published General Resolution 4953/2021 of 26 March 2021, providing further suspension up to 31 May 2021 regarding the initiation of prosecution
See MoreUS: IRS releases announcement and report concerning APMAs program
On 23 March 2021, the US IRS released an advance version of Announcement 2021-6 regarding the Advance Pricing and Mutual Agreement (APMA) program’s annual report on advance pricing agreements (APAs) for 2020. This twenty-second report
See MoreCosta Rica: Ministry of Finance issues resolution on APA procedures
On 24 March 2021, the Costa Rican Ministry of Finance released a Resolution No. DGT-R-14-2021, providing new guidelines on advance pricing agreements (APAs). The resolution provides the details guidelines of APAs procedures including definitions
See MoreUS: IRS publishes revised CFC practice unit guidelines
On 22 March 2021, the U.S. Internal Revenue Service has published a revised international practice unit on Receipt of Dividends or Interest from a Related CFC. This Unit was revised to include the extension of the IRC 954(c)(6) look through rule
See MorePuerto Rico extends tax returns and payments deadlines due to COVID-19 outbreak
On 23 March 2021, the Puerto Rico Treasury Department (PRTD) has issued Administrative Determination No. 21-04 extending the due date for income tax returns and tax payments due to the ongoing COVID-19 pandemic. As a general rule, individuals,
See MorePeru announces the most appropriate method in the case of intra-group services
On 18 March 2021, the Peruvian tax authorities (SUNAT) has issued Report No. 135-2020-SUNAT/7T0000, through which SUNAT announced the use of the most appropriate method to determine the market value of services other than those classified as low
See MoreEcuador: National Tax Authority amends rules on submission request for APAs
On 11 March 2021, the Deputy General Director of the Internal Revenue Service (SRI) Officially issued and signed Resolution No. NAC-DGERCGC21-0000001 in Spanish, which provides several changes to the transfer pricing regime on advance pricing
See MoreArgentina: Government proposes progressive corporate tax reform
In mid-March the government led by the president, Alberto Fernández, sent a bill to Congress that lays out the details of a progressive reform to corporate income tax. The latest reform being proposed by the Fernández administration would
See MorePanama extends tax return submission deadline for 2020
The Ministry of Economy and Finance of Panama has extended the deadline to 3 May 2021 for the submission of income tax returns (natural and legal persons) for the tax year 2020 in response to the Covid-19
See MoreJamaica: TAJ extends tax filing deadline due to COVID-19 pandemic
On 11 March 2021, Tax Administration Jamaica (TAJ) issued a press release extending the tax filing deadline due to COVID-19. TAJ extends the income tax filing deadline from 15 March 2021 to 31 March 2021. This means that companies, partnerships,
See MoreDominican Republic: DGII declares public consultation to amend TP rules
On 1 March 2021, the Directorate General of Internal Revenue (DGII) made an announcement of launching a public consultation on the draft modification of articles 5, 7, 10 and 18 of the transfer pricing (TP) regulation, established by means of the
See MoreArgentina: AFIP again extends suspension of prosecution proceedings for tax collection
In response to corona virus pandemic, on 25 February 2021, the Federal Public Revenue Administration (AFIP) published General Resolution 4936/2021 of 25 February 2021, providing further suspension up to 31 March 2021 regarding the initiation of
See MoreChile: BEPS MLI enters into force
On 1 March 2021, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, MLI entered into
See MoreUS: IRS publishes the interest rates on overpaid and underpaid tax for Q2 2021
On 2 March 2021, the Internal Revenue Service announced that interest rates for the calendar quarter beginning April 1, 2021. The rates are unchanged from the previous quarter. The rates are: 3% for overpayments (2% in the case of a
See MorePanama: Draft bill to introduce tax relief measures
The Cabinet of Panama has approved the Ministry of Finance to submit a draft bill in the National Assembly providing tax relief measures in response to the Covid-19 pandemic. Tax measures are following: Extension of the installment payment for
See MoreCanadian mining company wants to resolve its tax dispute with NAFTA arbitration
On 2 March 2021, a publicly traded Canadian mining company (First Majestic Silver), has resorted to international arbitration to resolve an ongoing transfer pricing dispute with the Mexican government over tax reassessments the government made in
See MoreUruguay extends advance tax payment deadline
On 10 February 2021, the Directorate General of Taxation (DGI) of Uruguay has declared Resolution No. 209/2021 regarding advance payment deadline extension for the month of January 2021 until March 2021 (generally due in February) in response to
See More