US: IRS and Treasury issue final regulations on foreign tax credits
On 12 November 2020, the Internal Revenue Service and Treasury published in the Federal Register providing guidance related to the allocation and apportionment of deductions and foreign taxes, foreign tax re-determinations, foreign tax credit
See MoreArgentina: AFIP provides further delay on inspections, assessments, appeals
In response to corona virus pandemic, on 9 November 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4856 of 9 November 2020, providing an additional suspension up to 29 November 2020 regarding inspections,
See MoreDominican Republic: DGII implements tax relief for facilitating tax compliances
On 8 October 2020, the Dominican Tax Authority (DGII) published General Rule 05-20, which provides implementation of tax amnesty and facility on tax compliances. According to the tax amnesty measures, taxpayers will be allowed to pay an amount
See MorePanama declares 5% income tax rate
According to Executive decree No. 241, Companies with a multinational company headquarters (SEM) license may be eligible for a tax incentive of a reduced 5% income tax rate. To be eligible for the reduced tax rate the company must: Have executed
See MoreUS and Singapore sign agreement on exchange of CbC reports
On 4 November 2020, IRS published the updated page on CbC reporting jurisdiction status table. Accordingly, on 6 October 2020, U.S. and Singapore have entered into a CAA for the automatic exchange of CbC reports. Pursuant to the provisions of
See MoreArgentina: AFIP provides suspension on inspections, assessments, appeals
In response to corona virus pandemic, on 26 October 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4840 of 26 October 2020, providing an additional suspension up to 8 November 2020 regarding inspections,
See MoreU.S. and Germany sign agreement on exchange of CbC reports
On 4 November 2020, IRS published the updated information on CbC reporting jurisdiction status table. Accordingly, on 14 August 2020, U.S. and Germany sign an agreement on exchange of Country-by-Country reports. Each Competent Authority intends
See MorePanama deposits its instrument of ratification for the Multilateral BEPS Convention
On 5 November 2020, Panama has deposited its instrument of ratification for the Multilateral Convention to implement tax treaty related measures to prevent base erosion and profit shifting (Multilateral Convention or MLI), which now covers almost
See MoreArgentina: AFIP extends suspension of prosecution proceedings for tax collection
In response to corona virus pandemic, on 29 October 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4847/2020 of 29 October 2020, providing further suspension up to 30 November 2020 regarding the blocking of
See MorePeru: SUNAT will be able to access and review the international tax and financial information
On 19 October 2020, the Peruvian Tax Administration (SUNAT) has issued Press release No. 101, where it was stated that SUNAT will be able to access and review the international tax and financial information of more than 16,000 companies and 33,000
See MoreUS: IRS updates parameters for APA and MAP
On 28 October 2020, the US Internal Revenue Service (IRS) published that it is updating parameters that the Advance Pricing and Mutual Agreement program (APMA), a representative office of the U.S. competent authority, will follow in implementing
See MoreArgentina: AFIP extends the deadline for beneficial ownership declaration
On 22 October 2020, the Tax Administration (AFIP) published General Resolution 4839/2020 of 22 October 2020 providing further relief from the beneficial ownership declaration for 2019 and disclosures on financial and non-financial trusts introduced
See MorePeru announces agreement for the exchange of financial account information
On 21 October 2020, the Peruvian tax authorities has announced that they will start the CRS Multilateral Competent Authority Agreement (CRS MCAA), the agreement for implementing the automatic exchange of financial account information under the
See MoreCosta Rica issues resolution on request for increased interest deduction limits
On October 15, 2020, Costa Rica published Resolution DGT-R-0032-2020, which outlines the application process for the taxpayer to increase the maximum deduction limit for net interest expense. The restriction on the deduction of interest expense was
See MoreArgentina: AFIP provides additional suspension regarding inspections, assessments, appeals
In response to corona virus pandemic, on 13 October 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4835 of 13 October 2020, providing an additional suspension up to 25 October 2020 regarding inspections,
See MoreUruguay extends estimated tax payment deadline
On 14 October 2020, the tax Authority of Uruguay published Resolution No. 1.898/020, extending the deadline for making estimated tax payments of corporate income tax (CIT), net wealth tax and corporation control tax to December 2020
See MoreUruguay declares tax exemption for software development services
The tax authority of Uruguay has issued Resolution No. 1716 to exempt corporate tax for income from software development services. Particularly, the tax authority permitted taxpayers to include, in their expenses and direct costs incurred in
See MoreEcuador: Government delays MCAA on automatic exchange of financial information
On 29 September 2020, the Organization for Economic Co-operation and Development (OECD) published an update regarding signatories of the multilateral competent authority agreement (MCAA) on automatic exchange of financial account information and
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