Dominican Republic: DGII declares public consultation to amend TP rules
On 1 March 2021, the Directorate General of Internal Revenue (DGII) made an announcement of launching a public consultation on the draft modification of articles 5, 7, 10 and 18 of the transfer pricing (TP) regulation, established by means of the
See MoreArgentina: AFIP again extends suspension of prosecution proceedings for tax collection
In response to corona virus pandemic, on 25 February 2021, the Federal Public Revenue Administration (AFIP) published General Resolution 4936/2021 of 25 February 2021, providing further suspension up to 31 March 2021 regarding the initiation of
See MoreChile: BEPS MLI enters into force
On 1 March 2021, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, MLI entered into
See MoreUS: IRS publishes the interest rates on overpaid and underpaid tax for Q2 2021
On 2 March 2021, the Internal Revenue Service announced that interest rates for the calendar quarter beginning April 1, 2021. The rates are unchanged from the previous quarter. The rates are: 3% for overpayments (2% in the case of a
See MorePanama: Draft bill to introduce tax relief measures
The Cabinet of Panama has approved the Ministry of Finance to submit a draft bill in the National Assembly providing tax relief measures in response to the Covid-19 pandemic. Tax measures are following: Extension of the installment payment for
See MoreCanadian mining company wants to resolve its tax dispute with NAFTA arbitration
On 2 March 2021, a publicly traded Canadian mining company (First Majestic Silver), has resorted to international arbitration to resolve an ongoing transfer pricing dispute with the Mexican government over tax reassessments the government made in
See MoreUruguay extends advance tax payment deadline
On 10 February 2021, the Directorate General of Taxation (DGI) of Uruguay has declared Resolution No. 209/2021 regarding advance payment deadline extension for the month of January 2021 until March 2021 (generally due in February) in response to
See MoreCanada: CRA announces not to pay cost recovery charge for APAs
On 5 February 2021, the Canada Revenue Agency (CRA) announced that they will no longer require taxpayers to provide a cost recovery charge when entering the Advance Pricing Arrangement (APA) program. Previously, the charge was used to cover the
See MoreArgentina: AFIP extends payment facility for SMEs
On 26 January 2021, the Federal administration of Public Revenue (AFIP) published General Resolution 4917/2021 of 26 January 2021 regarding the extension of tax payment facility for small and medium enterprises (SMEs) from 31 January 2021 until 31
See MoreCosta Rica: Legislative Assembly approves a bill to increase WHT rates
The Costa Rican Legislative Assembly has approved a bill considering to increase withholding tax rates on various types of income paid to non-residents by 5%. The bill provides the 20% withholding tax rates for dividends and interest, 30% for
See MoreEl Salvador: Ministry of Finance publishes interest rates for late tax payment
On 29 January 2021, the El Salvador's Ministry of Finance has issued a notice regarding interest rates for late tax payments during the period 1 February to 31 July 2021. This includes an annual interest rate of 6.77%, which is increased to 10.77%
See MoreArgentina: AFIP further extends suspension of prosecution proceedings for tax collection
In response to COVID-19 pandemic, on 29 January 2021, the Federal Administration of Public Revenue (AFIP) published General Resolution 4926/2021 of 29 January 2021, providing further suspension up to 28 February 2021 regarding the suspension of the
See MoreMexico sets threshold for reporting customized transactions under MDR
On 2 February 2021, Mexico has published Agreement 13/2021 in the Official Gazette. The Agreement sets threshold for reportable cross-border arrangements under the Mandatory Disclosure Regime (MDR). This Agreement is applicable from 3 February
See MoreDominican Republic: DGII publishes thresholds for TP reporting and some tax issues
On 4 February 2021, the Directorate General of Internal Revenue (DGII) published Resolution No. DDG- AR1-2021-00002, which provides various tax issues, including new transfer pricing thresholds and updates to its tax haven list. Transfer pricing
See MoreUruguay extends CbC reporting deadline to 28 February 2021
On 19 January 2021, Uruguay's Directorate General of Taxation (DGI) has published Resolution No. 075/2021 regarding the extension of the Country-by-Country (CbC) reporting deadline to 28 February 2021 for reporting fiscal years ending between 1
See MoreUS and Argentina sign CbC exchange arrangement
On 27 January 2021, US and Argentina have signed a competent authority agreement to exchange country-by-country reports. The purpose of the agreement is to increase international tax transparency and improve access of their respective tax
See MorePeru sets deadlines for individual and CIT returns for 2020
On 30 December 2020, the Peruvian tax authorities (SUNAT) has issued Resolution No. 000229 -2020/SUNAT in the official gazette regarding the deadlines for individual and corporate tax (CIT) returns for 2020. The Resolution includes an
See MoreParaguay introduces new guidance on TP law
On 30 December 2020, the tax authority of Paraguay issued Decree 4644/2020, providing further guidance on the technical aspects of Paraguay’s transfer pricing (TP) provisions included in Law 6380. Law No. 6,380/2019 modernized the Paraguayan
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