US: JCT releases overview of the limitation on the deduction of business interest
On 28 March 2019, the U.S. Joint Committee on Taxation (JCT) published an overview of the limitation on the deduction of business interest expense under Section 163(j) of the Internal Revenue Code as introduced by the Tax Cuts and Jobs Act. The new
See MoreNicaragua publishes tax law for 2019
On 28 February 2019, Nicaragua issued tax amend law No.987 in the Official Gazette including notices of the amendment of applicable withholding tax rates. Major changes are summarized in below: Establishing the changes in the alternative
See MorePeru: SUNAT simplifies the scope of the CFC rules
On 19 March 2019, the Peru tax authority (SUNAT) issued a guidance (No. 011-2019-SUNAT/7T0000) regarding the determination of expenses and loss offsetting under the controlled foreign company (CFC) rules. The guidance clarified that:
See MoreUruguay extends CbC Reporting deadline to 30 April 2019
According to Resolution No. 860/2019 of 27 March 2019, Uruguay's Directorate General of Taxation has extended the deadline for the submission of Country-by-Country Report (CbCR) to 30 April 2019 in respect of the reporting fiscal year ending 31
See MoreArgentina introduces installment payment option for tax assessment cases before the tax court
On 01 March 2019, the Federal Administration of Public Revenues (AFIP) has published General Resolution 4434 in the official gazette introducing an installment payment facility for tax liabilities in relation to tax assessments that are under
See MoreVenezuela extends deadline to file income tax return
On 26 March 2019, Venezuela’s Tax Administration declared the extension date to file income tax return for the fiscal year 2018 because of national power outages. The new date for filling annual income tax return is 30 April
See MoreIndia and USA sign inter-governmental agreement for exchange of CbC reports
On 27 March 2019, India and the US signed an Inter-Governmental Agreement for exchange of Country-by-Country (CbC) reports of multinational companies regarding income allocation and taxes paid to help check cross-border tax evasion. This
See MoreArgentina publishes tax incentive scheme for local production of certain capital goods
27 March 2019 On 15 March 2019, Argentina published Decree 196/2019 in the official gazette amending Decree No. 379 which was issued in 2001. The decree amends and extends one year (from January 1 to December 31, 2019) tax incentives for the
See MorePeru: SUNAT extends the deadline for submission of CbC reports for fiscal years 2017 and 2018
On 14 March 2019, the Peruvian tax authorities (SUNAT) issued an administrative regulation (Ruling No.054-2019) that extends the deadlines for the local filing of the CbC reports for Fiscal years 2017 and 2018. This resolution is effective as of the
See MorePuerto Rico extends the due date for filing 2018 informative returns
On 27 February 2019, The Puerto Rico Treasury Department issued Internal Revenue Informative 19-06 to extend the filing date this year to 15 March 2019. The provisions of Bulletin No.19-06 are effective as from 27 February 2019. Pursuant to Sections
See MoreColombia: Tax Authority updates forms for filing tax returns in 2019
On 7 March 2019, the National Tax Authority (DIAN) of Colombia published an administrative regulation and updated the withholding tax return forms (Form 350) for 2019. According to Annex 2, the following payments are made to resident in
See MoreCanada: Federal budget 2019
On 19 March 2019, Finance Minister Bill Morneau tabled in the House of Commons the Liberal Government’s Budget 2019. This budget focuses on continued economic growth, job creation, support for first-time home buyers, investments in cleaning up
See MoreUS: APMA releases new functional cost diagnostic model (FCD model) for APA submissions
On 26 February 2019, Advance Pricing and Mutual Agreement (APMA) program of IRS, released an excel based functional cost diagnostic model (FCD Model) that is developed in connection with several prior and pending Bilateral Advance Pricing
See MoreArgentina updates compensatory interest rate
On 8 February 2019, Argentina has published resolution 50/2019 of 7 February 2019 in the official gazette updating the compensatory interest rate and punitive interest rate established in articles 37 and 52 of Law No. 11,683 and the Customs Code
See MoreBolivia updates list of tax haven jurisdiction
On 15 February 2019, Bolivia's National Tax Service issued Resolution No. 101900000002 to update the list of jurisdictions considered to have low or no taxation, which also contains jurisdictions recognized as non-cooperative, applies from the date
See MoreDominican Republic reissues simplified tax regime for micro-enterprises
On 23 January 2019, The Dominican Republic’s Directorate General of Internal Revenue (DGII) announced a proposal to reissue the simplified tax regime for micro-enterprises. The regime would be available for businesses with revenue up to USD171,825
See MoreCosta Rica: MOF publishes resolution on tax residence certificates
On 19 February 2019, Costa Rica's Ministry of Finance (MOF) published a Resolution (was first published in the Official Gazette on 4 February 2019), which provides rules on the determination of tax residence and the issuance of residence
See MoreChile: IRS amends the annual transfer pricing form
The Internal Revenue Service (IRS) has issued a new version of the annual transfer pricing tax return (Form 1907) to be used in 2019, and includes new sections on Country Reporting (CbC). The IRS also added the instructions of the 1907
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