Peru: SUNAT issues guidance on comparability analysis using multi-year data
On 29 April 2021, the Peruvian tax authorities (SUNAT) has issued Administrative Guidance No. 036-2021-SUNAT/7T0000 providing guidance in relation to the use of multi-year data in determining arm's length transfer pricing. The guideline provides
See MoreOECD: Revenue Statistics for Latin America and the Caribbean 2021
On 22 April 2021 the OECD published Revenue Statistics in Latin America and the Caribbean 2021 . This is a joint publication of the OECD with the Inter-American Center of Tax Administrations (CIAT), the Economic Commission for Latin America and the
See MoreCosta Rica extends the filing due date for ultimate beneficiary owner return
On 29 April 2021, Costa Rica published the Resolution No. DGT-ICD-R-17-2021 extending the due date for filing the ultimate beneficial owner return in the registry for the year 2021. Originally, the deadline to comply with this obligation was on
See MoreChile: Tax authority extends deadline of income tax return and payments for SMEs
On 30 April 2021, the Tax authority declared that taxpayers may file their 2021 income tax declaration until 31 May 2021, as a way to facilitate compliance with this tax responsibility, which occurs in a period marked by the health emergency and
See MoreDominican Republic: DGII issues a Decree to amend TP rules
On 21 April 2021, the Directorate General of Internal Revenue (DGII) published Decree 256-21, which makes modification on articles 5, 7, 10 and 18 of the transfer pricing (TP) regulation, established by means of the Decree no. 78-14, of March 14,
See MoreColombia extends payment deadline for micro and small companies
On 9 April 2021, the Colombian Ministry of Finance and Public Credit has published Decree No. 374 by which the corporate income tax payment of micro and small companies has been extended amid COVID-19 pandemic. The first installment is between 9
See MoreCanada: 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
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