Canada: Finance Minister presents Budget 2021
On 19 April 2021, the Finance Minister, Chrystia Freeland, presented Budget 2021, which includes important business tax measures, digital service taxes, limitation of interest deduction, hybrid mismatch arrangements, transfer price cases, mandatory
See MoreUS: IRS extends e-signature authorization for submitting APA and MAP requests
On 15 April 2021, the IRS released an updated memo on e-signature requirements extending the authorization to electronically sign a large number of IRS forms until Dec. 31, 2021, and adding a number of new forms. The original authorization was
See MoreColombia reduces advance payment of income tax for 2021
On 9 April 2021, the Colombian Ministry of Finance and Public Credit has published Decree No. 375, through which it reduces the advance payment to be made by income taxpayers in the year 2021 as a consequence of the emergency generated by
See MoreColombia: Government submits Tax Reform Bill to Congress
On 15 April 2021, the Colombian government has submitted new Tax Reform Bill (Sustainable Solidarity Act) to Congress. The Bill modifies corporate income tax (CIT), value-added tax (VAT) and personal income tax. The main tax measures of the Tax
See MorePeru: SUNAT reduces late payment interest rate from April 2021
On 30 March 2021, the Peruvian tax authorities (SUNAT) has issued Resolution 000044-2021/SUNAT in the Official Gazette, through which SUNAT has decided to reduce the late payment interest rate from 1% to 0.9% per month on the amount of tax due with
See MoreBrazil: Revenue extends the submission deadline of individual tax return
On 12 April 2021, the Federal Revenue Officially published the RFB Normative Instruction 1930/2020, which changed the deadline for reporting the Annual Adjustment Statement of the Individual’s Income Tax Return for 2021 from 30 April 2021 until
See MorePanama further extends tax return submission deadline for 2020 tax year
According to Decree No. 110 of 31 March 2021, Panama's Ministry of Economy and Finance has extended the deadline for the submission of income tax returns to 17 May 2021 for the 2020 tax year, which follows a previous extension to 3 May 2021. In
See MoreChile: 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,
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