Canada CRA publishes a notice regarding the effect of MFN provisions with Lithuania
Recently, the Canada Revenue Agency (CRA) has published a Notice regarding the impact on the Most Favoured Nation (MFN) provision of the Canada–Lithuania Income Tax Convention with respect to certain royalties. Effective January 1, 2019, the
See MoreCanada: CRA publishes a notice regarding the effect of MFN provisions with Latvia
Recently, the Canada Revenue Agency (CRA) has published a Notice regarding the impact on Most Favoured Nation (MFN) provision of the Canada–Latvia Income Tax Convention with respect to certain royalties. Effective January 1, 2018, the
See MorePanama amends CbC reporting penalties
On 11 November 2021, Panama published Law No. 254 in the Official Gazette No. 29413-A, which amends the legislation on international tax transparency and the prevention of money laundering, and the financing of terrorism. The significant
See MoreUS: Tax Court refuses for reconsideration in transfer pricing dispute
On 26 October the US Tax Court has denied Coca-Cola’s motion for leave to file out of time a motion for reconsideration on the grounds that the application for leave would be “futile” as the court would, since the court will ultimately
See MoreUS and Turkey sign CAA regarding CbC exchange arrangement
On 24 November 2021, US and Turkey have signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. A CbC report is intended to be first exchanged with respect to Fiscal Years of MNE Groups commencing on or after 1
See MoreUS and India reach agreement on ‘equalization levy’ digital services tax
On 24 November 2021, the United States and India concluded an agreement on a transitional approach to the treatment of the current Indian E-commerce Equalization Levy (EL) in the transition period prior to the full implementation of Pillar 1
See MoreUS and Turkey sign digital service tax agreement
On 22 November 2021, the U.S. treasury department announced that the United States and Turkey have reached a political agreement with Turkey on the treatment of taxes on digital services (DST) in the transition period prior to the full
See MoreDominican Republic: DGII describes a guide regarding FTC
The Tax Authority has recently made a clarification through a Public Ruling, GLN 25641, regarding foreign tax credit (FTC) as well as unilateral relief methods. According to the letters, the maximum foreign income tax credit paid to a foreign
See MoreUS: IRS releases interest rates on overpaid and underpaid tax for Q1 of 2022
On 23 November 2021, the Internal Revenue Service announced that interest rates will remain the same for the calendar quarter beginning January 1, 2022. The rates will be: 3% for overpayments (two (2) percent in the case of a corporation),0.5%
See MoreMexico: Congress approves Economic Package for the fiscal year 2022
On 26 October 2021, Mexican Congress has approved the tax reform for 2020 which was presented for the fiscal year 2022 which was presented on 8 September 2021. The Economic Package clarifies income tax law, value-added tax (VAT) law, excise tax
See MoreColombia reduces interest and penalties in response to COVID-19
On 29 October 2021, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales-DIAN) has issued Resolution No. 000126, through which DIAN has temporarily reduced penalties to 20% and a default interest rate of 20% of the
See MoreColombia issues Draft Resolution to set UVT for 2022
On 8 November 2021, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales-DIAN) has issued a Draft Resolution to set out the tax unit value (Unidad de Valor Tributario – UVT) applicable for the year 2022. The UVT is
See MoreColombia: Government issues regulations identifying preferential tax regimes
On 28 October 2021, the Colombian Government has issued Decree 1357, through which it partially regulates article 260-7 of the Tax Code. The Decree identifies criteria to consider a jurisdiction as a Preferential Tax Regime. This decree was
See MorePeru: Government submits Tax Reform Bill to Congress
On 27 October 2021, the Government led by President Pedro Castillo has submitted a bill to Congress through which it requests extraordinary powers to legislate on tax matters. The main measures of the Bill are as follows: Increase of capital
See MoreDominican Republic: DGII describes a guide on foreign tax credit
The Tax Authority has recently made a clarification through a guide, GLN 25641, regarding foreign tax credit (FTC) as well as unilateral relief methods. The following instructions are effective immediately and have included in the Tax Code: The
See MoreDominican Republic: Government establishes thresholds and filing obligation of CbC report
On 5 October 2021, the Government established specific regulations for the country-by-country report through general standard on August 2021. The general rule is aligned with the model legislation included in the OECD’s base erosion and profit
See MoreBrazil: STF decides that interest on late tax refunds is non-taxable
On 24 September 2021, the Federal Supreme Court (Supremo Tribunal Federal, STF), ruled Extraordinary Appeal No. 1.063.187) that certain interest that a taxpayer receives on a late tax refund from the treasury should not be included in the
See MoreEl Salvador: Legislative Assembly approves tax amnesty until 10 December
On 5 October 2021, at the request of the Ministry of Finance, the Legislative Assembly approved Legislative Decree 173 known as Tax Amnesty. The decree aims to give taxpayers 60 days to settle their situation before the Treasury, with exemption
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