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
See MoreUS: IRS publishes interest rates on overpaid and underpaid tax for Q4 of 2022
On 15 August 2022, the Internal Revenue Service announced that interest rates will increase for the calendar quarter beginning October 1, 2022. For individuals, the rate for overpayments and underpayments will be 6% per year, compounded daily, up
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OECD: Peer Review Report on Tax Transparency in Ecuador
On 16 August 2022 the Global Forum for Transparency and Exchange of Information for Tax Purposes released a second round (phase 1) peer review report in relation to Ecuador. The peer review report examines the legal and regulatory framework in
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Colombia: New Government presents Tax Reform Bill to Congress
On 8 August 2022, the new Government of Colombia presented a Tax Reform Bill to Congress. Although the general income tax rate (35%) is not modified, the Bill includes changes in corporate income tax (CIT), and personal income tax. The main tax
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Costa Rica: DGT extends the deadline for filing dormant entities tax returns
The General Directorate of Taxation has extended the deadline for filing income tax returns for dormant companies until 15 November 2022. A dormant company is considered a company that meets the conditions defined in Circular 2014/2. The return must
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Canada: Consultation on Strengthening the General Anti-Avoidance Rule
On 9 August 2022 the Canadian government published a consultation paper on strengthening the general anti-avoidance rule (GAAR). Comments are invited by 30 September 2022. The paper notes that the GAAR, which was first introduced in 1988, has
See MoreParaguay extends deadlines of TP returns
On 23 June 2022, the tax authority has extended the deadlines to submit the transfer pricing (TP) informative returns related to commodities exports through General Resolution 116. The Resolution came into force on 24 June 2022. The deadlines are
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Canada enacts Budget for 2022
Canada has published the Budget Implementation Act, 2022, No. 1, which received royal assent on 23 June 2022 and provides for the implementation of certain measures proposed as part of the Budget 2022. Key measures in Budget Bill C-19 include:
See MoreArgentina issues resolution increasing thresholds for advance payments
On 28 June 2022, Argentine Official Gazette published General Resolution 5211/2022 amending the provisions on income tax advance payment. The resolution increases the thresholds for making advance payments from ARS 500 to ARS 2500. Companies are
See MoreCosta Rica: Ministry of Finance reduces interest rate for late payments
On 24 June 2022, the Costa Rican Ministry of Finance has published the resolution RES-DGH-026-2022/RES-DGA-187-2022 providing to decrease the interest rate applicable on late payments of taxes, surcharges and penalties, and on tax refunds.
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