Canada deposits ratification instrument for MLI
On 29 August 2019, Canada deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures (MLI) to Prevent Base Erosion and Profit Shifting. The MLI would enter into force on the first day of the
See MoreMexico: Tax reform proposal in economic package 2020
On 8 September 2019, Mexican president Andrés Manuel López Obrador’s presented Economic Package for the fiscal year 2020 to Congress. The economic package proposed following tax reform measures: Transparent Entities International
See MoreColombia: Reminder on tax amnesty deadline
It’s a reminder for the Colombian taxpayers wishing to take part in ongoing tax amnesties. The Colombian 2019 tax reform establishes a tax amnesty to “normalize” (i) unreported assets; or (ii) nonexistent liabilities that were included on a
See MorePanama updates penalty provision to tackle tax evasion
Cabinet Council of Panama has approved a proposed legislative amendment to strengthen the penalty provision for repeated tax evasion. The proposal follows the enactment of law 70 of 31 January 2019, which criminalizes tax evasion for the first
See MoreBrazil: Federal representatives publishes their comments under PEC 45/2019
On 11 September 2019, the representatives of all federal States submitted their comments on the tax reform proposal under the Bill for Amendment of the Constitution 45/2019 (PEC 45/2019). This proposed amendment seeks to promote a comprehensive
See MoreCosta Rica: Government announces the budget for 2020
On 30 August 2019, Costa Rican government presented the 2020 budget to the Legislative Assembly which is 4.3% lower than in 2019, thus representing the largest spending reduction in recent years. The tax reform adopted by Congress in December is
See MoreColombia: DIAN issues resolution on MAP
On 13 August 2019, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales, DIAN) has published Resolution No. 000053 in the official gazette which establishes Mutual Agreement Procedure (MAP) to avoid double taxation and
See MoreUS: Protocol to income tax treaty with Japan enters into force
On 30 August 2019, the U.S. treasury department announced that protocol amending the convention between the government of the United States of America and the government of Japan for the avoidance of double taxation and the prevention of fiscal
See MoreUS: IRS publishes interest rates on overpaid and underpaid tax for the 4th quarter of 2019
On 28 August 2019, the Internal Revenue Service announced interest rates on overpaid and underpaid tax for the calendar quarter beginning 1 October 2019 that will remain the same, as they were in the prior quarter. The rates will be 5% for
See MoreUS: Court of Appeals approves Tax Court’s decision in Transfer Pricing case
On 16 August 2019, the U.S. Court of Appeals for the Ninth Circuit in the case of: Amazon.com, Inc. v. Commissioner, 148 T.C. 108 (2017) issued a decision in favor of Amazon concerning the regulatory definition of intangible assets and the
See MoreChile: Chamber of Deputies approves tax reform bill
On 23 August 2019, the tax reform Bill was passed by the Chamber of Deputies. The tax changes in the reform bill include: a new definition of permanent establishmentsa new concept for tax deductible expenses;the introduction of green taxes; anda
See MoreChile approves protocol to DTA with China
The Chamber of Deputies of Chile approved the bill for ratifying the pending protocol of Double Taxation Agreement (DTA) with China for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. It is
See MoreUS: IRS withdraws “Altera Memo” directive on cost-sharing arrangements
On 5 August 2019, the U.S. IRS published a memorandum dated 31 July 2019 on the formal withdraw of Directive LB&I-04-0118-005. Directive LB&I-04-0118-005 was issued on 12 January 2018 and provided instructions for examiners on transfer
See MoreDominican Republic: Government introduces new simplified tax regime for small taxpayers
The Dominican Republic published Presidential Decree No. 265-19 of 1 August 2019, which introduces a new simplified tax regime (RST) for small entities. This previous simplified tax regime is canceled and RST is applicable for both legal and
See MoreArgentina amends the compensatory and punitive interest rates
On 18 July 2019, Argentine Federal Secretary of Treasury published Resolution 598/2019 in the official gazette amending Resolution 50/2019 on compensatory and punitive interest rates. According to the Resolution 50/2019, current effective
See MoreBulgaria approves CbC Exchange Agreements with U.S.
On 10 July 2019, Bulgaria's Council of Ministers approved two agreements with the United States allowing for the automatic exchange of country-by-country reports. The CbC report is one element of the three-tiered standardized approach to transfer
See MorePeru: SUNAT issues resolutions on GAAR
On 31 July 2019, the Peruvian Tax Administration (SUNAT) published two resolutions (152-2019/SUNAT and 153-2019/SUNAT) regarding general anti-avoidance rule (GAAR) in the Official Journal. The two resolutions are summarized below: Resolution
See MoreColombia: DIAN issues ruling on tax treatment of stock dividends
Recently, the Colombian National Tax Authority (DIAN) published Ruling 014495 of 6 June 2019, which sets out tax of profits in shares or stock dividend. The ruling includes the following points: Article 30 of the Tax Code (TC) provide the
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