Canada: CRA extends payment deadline of income tax return
On 27 July 2020, the Canada Revenue Agency (CRA) announced that payment deadline for the year 2020 of the income tax returns, including installments for legal entities, trust, and individual is to be extended from 1 September 2020 to 30 September
See MorePuerto Rico extends certain filing and payment due dates due to ‘Isaias’
On 3 August 2020, the Puerto Rico Treasury Department has published Administrative Determination No. 20-20 of 31 July 2020 postponing all filing and payment deadlines until 7 August 2020 that were due 31 July 2020 due dates due
See MoreUS and Switzerland sign competent authority arrangement on implementation of arbitration
On 28 July 2020, U.S. and Switzerland signed an agreement for the implementation of the arbitration process provided for in Article 25 (Mutual Agreement Procedure) of the 1996 income tax treaty between the two countries as amended by the 2009
See MoreColombia issues decree on taxation of investment funds and PEs
On 19 July 2020, the Colombia Ministry of Finance and Public Credit has issued Decree 1054 of 2020, which determines the scope in tax matters of the concepts taxation of investment funds and (permanent establishments) PEs. The Decree was issued
See MoreUS: IRS issues final regulations and other guidance on business interest expense deduction limitation
On 28 July 2020, the Internal Revenue Service issued final regulations regarding the provision of the Tax Cuts and Jobs Act that limits the deduction for business interest expense, including basic statutory amendments made by the CARES Act. For
See MoreArgentina: AFIP amends traditional deadlines for TP documentation submission
On 13 July 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4759/2020 of 8 July 2020, which make slight amendments in the transitional submission deadlines of the new Form F. 2668, the Transfer Pricing Study,
See MoreChile: Senate approves the ratification of BEPS MLI
On 9 July 2020, the Senate approved the ratification of multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). After the ratification process, Chile will need to deposit its ratification instrument to bring the
See MoreDominican Republic: DGII issues notices to extend tax payment relief due to COVID-19 pandemic
The Directorate General of Internal Revenue (DGII) issued Notice 76-20, which provides extension of the tax payment relief previously given by Notice 36-20 due to COVID-19 pandemic. Notice 36-20 extends the tax payments by three months, which were
See MoreArgentina: AFIP announces suspension regarding tax audit, social security and customs duties
On 20 July 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4766 of 20 July 2020, which provides additional postponement of the terms for inspections, assessments, appeals, reimbursements, and other procedures
See MorePanama further extends tax returns filing deadline
On 16 July 2020, Panama has published Decree No. 356 in the Official Gazette regarding further extensions of certain deadlines due to the Covid-19 pandemic. Annual tax return filing deadline for the 2019 tax year was previously extended to
See MoreUruguay extends additional advance payment deadline
The Directorate General of Taxation (DGI) of Uruguay has announced Resolution No. 1251/2020 of 16 July 2020 concerning additional advance payment deadline extensions in response to the Covid-19 pandemic. The taxpayers with taxable gross
See MoreDominican Republic: The DGII extends corporate tax return deadline
On 15 July 2020, the Directorate General of Internal Revenue (DGII) released a Notice 80-20 to announced that the submission deadline of corporate tax return and payment of tax for the tax year closed 31 March 2020 is extended until 31 August 2020.
See MoreBrazil: Bill proposes different COFINS tax regime in COVID-19 pandemic
Recently, the Senate proposed through the Complementary Bill 131/2020 different tax regime for the Contribution to the Financing of Social Security (COFINS) levied on the gross revenue earned by legal entities with high revenue using digital
See MoreChile: Tax authority suspends advance corporate tax payments and VAT payments
On 8 July 2020, the tax authority published a Resolution 76/2020 to suspend the provisional corporate tax payments obligations for the months July, August, and September 2020 respectively. Note that, this relief applies to micro, small and
See MoreCanada: Federal Court of Appeal makes a decision in a transfer pricing case
On 26 June 2020, the Federal Court of Appeal made decision in a transfer pricing case, entitled “The Queen v. Cameco Corporation, 2020 FCA 112” in favour of the taxpayer, i.e. Cameco Corporation. The Cameco Corporation, together with its
See MoreEcuador: The Internal Income Service amends prior Resolutions regarding transfer pricing
On 1 July 2020, the Government published Resolution No. NAC-DGERCGC20-00000046 of 1 July 2020, which amends the calculation of profit level indicators. According to amendments, it is provided that taxpayers must use the last financial information
See MoreUS: Treasury Department and IRS issue guidance for group’s net operating losses
On 2 July 2020, the Department of the Treasury and the Internal Revenue Service issued proposed regulations and temporary regulations that provide guidance for consolidated groups regarding net operating losses (NOLs). The Tax Cuts and Jobs
See MoreArgentina: AFIP amends new tax payment facility in response to COVID-19 pandemic
On 26 June 2020, the Federal Administration of Public Revenue (AFIP) published General Resolution 4742/2020 of 25 June 2020, which amends General Resolution 4718/2020 of 15 May 2020. This new Resolution extends the deadline to apply for the payment
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