Peru: SUNAT provides a list of high-risk tax planning schemes regarding GAAR
On 5 February 2020, the Peruvian Tax Administration (SUNAT) has published first version of the list of high-risk tax planning schemes regarding General Anti-Avoidance Rule (GAAR). The list contains the following five tax planning
See MoreColombia publishes decree amending the taxation of dividend income
On 31 December 2019, the Colombian Ministry of Finance and Public Credit (MinHacienda) has published Decree 2371 of 27 December 2019 on its website which amends the dividend income tax. The Decree regulates the tax and withholding tax on dividends
See MoreArgentina: Government publishes General Resolution on tax schemes for SMEs
On 31 January 2020, Government published General Resolution 4667/2020 of 30 January 2020, which provides special tax schemes for small and medium enterprises (SMEs) introduced by Law 27541 on Social Solidarity and Productive Reactivation. This
See MoreDominican Republic: DGII publishes list of territories not considered tax heavens
The Directorate General of Internal Revenue (DGII) issued Notice 10-20 regarding an updated list of States that are not considered tax heaven or preferential tax regimes. The list includes the following territories: Antigua and Barbuda,
See MoreColombia: DIAN issues new guidelines for GAAR
On 15 January 2020, Colombian tax authority (DIAN) has published Executive Order No. 4 of 7 January 2020 in the official gazette where DIAN clarifies the application of General Anti-Avoidance Rule (GAAR). The GAAR provisions are contained in
See MoreChile: Senate approves Tax Reform Bill
On 29 January 2020, the Senate approved a Tax Reform Bill. Once in force, the proposed measures will generally apply as from 1 January 2020, except the VAT requirements for digital services, which will be implemented three months after the law is
See MoreUruguay extends deadline for CbC reporting
The Directorate General of Taxation of Uruguay has published Resolution No. 234/2020 of 31 January 2020 to extend the Country-by-Country (CbC) reporting deadline to 15 March 2020 for reporting fiscal years ending between 1 January 2019 and 28
See MoreCosta Rica gazettes moratorium on penalties for non-compliance of ultimate beneficiary register
On 30 January 2020, the Costa Rican Official Gazette published a law introducing a three-month moratorium on the Registry of Transparency and Final Beneficiaries (RTBF) registration penalties for the 2019 tax year. The Registry was established as
See MorePeru: SUNAT explains carry forward loss rules for R&D incentives
On 23 January 2020, the Peruvian Tax Administration (SUNAT) has published Report No. 200-2019-SUNAT/7T0000 on its website regarding tax carry forward loss rules for research and development (R&D) incentives. SUNAT clarifies that the R&D
See MoreVenezuela: Government publishes decrees regarding tax reform
On 29 January 2020, three decrees were published in the Official Gazette for introducing a new tax code, amending the VAT Law and customs Law. It was approved by the Constituent Assembly on the similar day. Withholding taxes due One of three
See MoreEcuador: SRI publishes Resolution regarding temporary corporate income tax
On 29 January 2020, the Internal Revenue Service (SRI) published an Administrative Resolution in the Supplement of the Official Registry 131, which specifies the procedure for filing the tax return and the annual payment of the temporary tax for
See MorePanama extends CbC reporting deadline and notification again
On 31 January 2020, Directorate General of Revenue of Panama has issued Resolution No. 201-1035 in the official gazette, which extends the deadline for filing the Country by Country Report (CbC) and the Notification as well. The Resolution
See MorePuerto Rico amends income tax law for deduction of intercompany charges
Recently, Puerto Rico has amended Section 1033.17(a)(17) of the Puerto Rican Internal Revenue Code of 2011 regarding intercompany expense allocation. Previously there was a disallowance of 51% of intercompany charges. According to the amendment,
See MorePanama introduces CbC registration process via AEOI portal
The FATCA & AEOI Portal of Panama's Directorate General of Revenue (DGI) is now accepting registration for Country-by-Country (CbC) report presentation and notification purposes, as well as for FATCA and CRS purposes. The CbC reporting
See MoreDominican Republic: DGII issues transfer pricing documentation thresholds for 2020
On January 15, 2020, Directorate General of Internal Revenue (DGII) published the Transfer pricing (TP) reporting threshold for 2020. The related party transaction threshold for transfer pricing reporting purposes in 2020 is DOP11,552,402. The
See MoreCanada: Reminder for the CbC reporting form submission process
On 9 January 2020, Government announced that as from 1st June 2020, Canadian ultimate parent entities that are corporations must file the RC4649 electronically using EFILE or Web Access Code (WAC). It will be available through CRA-T2-certified
See MoreArgentina: Government publishes General Resolution on dividend WHT rate
On 14 January 2020, the Government issued a General Resolution 4662/2020, which establishes procedures and deadlines for withholding tax payments on dividends paid by a permanent establishment to its parent company. With effect as from 14 January
See MoreCosta Rica: Ministry of finance publishes draft resolution on tax benefit for SMEs
The Costa Rican Ministry of Finance recently published a draft resolution on tax benefits for SMEs that was introduced by Law No. 9635 of 3 December 2018. The benefits apply to qualified SMEs whose gross income does not exceed CRC 106 million
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