US: North Carolina announces voluntary corporate transfer pricing resolution initiative
On 30 July 2020, the North Carolina Department of Revenue announced that it is implementing a voluntary initiative to expedite the resolution of corporate intercompany pricing issues. The purpose of this initiative is to fairly and consistently
See MorePanama considering tax cuts for SME sector amid Covid-19 pandemic
On 27 July 2020, Panama's National Assembly submitted two draft bills that contain measures in response to the Covid-19 pandemic. The bill No. 358 provides reduced income tax rates for companies and individuals qualifying as SMEs that would
See MoreCosta Rica postpones VAT rules on cross-border digital services for two month
On 31 July 2020, Costa Rica published a directive that delayed the introduction of VAT rules on cross-border digital services by two months. Initially, the effective date was set for 1 August 2020. From October 1, 2020, VAT at 13% must be
See MoreColombia: DIAN starts a new system for the registration of commodity agreements
On 3 August 2020, the Colombian tax authority (DIAN) has launched an online system for registering commodities agreements for the purposes of carrying out commodity operations with related parties from abroad or in the Free Trade Zone or third
See MoreMexico modifies the General Customs Rules for 2020
On 24 July 2020, Mexico has published the first amendment to the General Customs Rules for 2020 in the Official Gazette. The amendments include changes to the Comprehensive Business Certification Scheme, in the VAT, VAT Certification and Authorized
See MoreArgentina: AFIP announces additional suspension regarding inspections, assessments, appeals
On 8 August 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4786 of 3 August 2020, which provides an additional postponement in case of inspections, assessments, appeals, reimbursements, other methods related
See MoreUS: IRS publishes revised practice unit on dividends or interest from a related CFC
On 29 July 2020, the U.S. IRS published a revised international practice unit on the Receipt of Dividends or Interest from a Related CFC. The practice unit was revised to include the extension of the IRC 954(c)(6) look through rule for CFCs with
See MoreCanada: CRA extends payment deadline of income tax return
On 27 July 2020, the Canada Revenue Agency (CRA) announced that payment deadline for the year 2020 of the income tax returns, including installments for legal entities, trust, and individual is to be extended from 1 September 2020 to 30 September
See MorePuerto Rico extends certain filing and payment due dates due to ‘Isaias’
On 3 August 2020, the Puerto Rico Treasury Department has published Administrative Determination No. 20-20 of 31 July 2020 postponing all filing and payment deadlines until 7 August 2020 that were due 31 July 2020 due dates due
See MoreUS and Switzerland sign competent authority arrangement on implementation of arbitration
On 28 July 2020, U.S. and Switzerland signed an agreement for the implementation of the arbitration process provided for in Article 25 (Mutual Agreement Procedure) of the 1996 income tax treaty between the two countries as amended by the 2009
See MoreColombia issues decree on taxation of investment funds and PEs
On 19 July 2020, the Colombia Ministry of Finance and Public Credit has issued Decree 1054 of 2020, which determines the scope in tax matters of the concepts taxation of investment funds and (permanent establishments) PEs. The Decree was issued
See MoreUS: IRS issues final regulations and other guidance on business interest expense deduction limitation
On 28 July 2020, the Internal Revenue Service issued final regulations regarding the provision of the Tax Cuts and Jobs Act that limits the deduction for business interest expense, including basic statutory amendments made by the CARES Act. For
See MoreArgentina: AFIP amends traditional deadlines for TP documentation submission
On 13 July 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4759/2020 of 8 July 2020, which make slight amendments in the transitional submission deadlines of the new Form F. 2668, the Transfer Pricing Study,
See MoreChile: Senate approves the ratification of BEPS MLI
On 9 July 2020, the Senate approved the ratification of multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). After the ratification process, Chile will need to deposit its ratification instrument to bring the
See MoreDominican Republic: DGII issues notices to extend tax payment relief due to COVID-19 pandemic
The Directorate General of Internal Revenue (DGII) issued Notice 76-20, which provides extension of the tax payment relief previously given by Notice 36-20 due to COVID-19 pandemic. Notice 36-20 extends the tax payments by three months, which were
See MoreArgentina: AFIP announces suspension regarding tax audit, social security and customs duties
On 20 July 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4766 of 20 July 2020, which provides additional postponement of the terms for inspections, assessments, appeals, reimbursements, and other procedures
See MorePanama further extends tax returns filing deadline
On 16 July 2020, Panama has published Decree No. 356 in the Official Gazette regarding further extensions of certain deadlines due to the Covid-19 pandemic. Annual tax return filing deadline for the 2019 tax year was previously extended to
See MoreUruguay extends additional advance payment deadline
The Directorate General of Taxation (DGI) of Uruguay has announced Resolution No. 1251/2020 of 16 July 2020 concerning additional advance payment deadline extensions in response to the Covid-19 pandemic. The taxpayers with taxable gross
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