Brazil: Federal Revenue approves Private Ruling 276/2019
On 2 October 2019, the Brazilian tax authorities released a private ruling PLR 276/2019 on tax treatment of cross-border cost sharing arrangements. The ruling provides a consultation solution that was requested by an entity whose direct parent
See MorePeru: SUNAT publishes resolution on submission of CbC reports
On 29 September 2019, the Peruvian Tax Administration (SUNAT) has published Resolution No. 188-2019/SUNAT in the Official Gazette, through which the comprehensive system for the reception and automatic exchange of information (IR AEOI system) was
See MoreArgentina: AFIP announces draft transfer pricing guidance for public comments
On 2 October 2019, tax authority of Argentina (AFIP) announced a public consultation and posted on the AFIP website a draft resolution concerning transfer pricing compliance procedures. It would replace the existing transfer pricing rules in
See MorePeru: SUNAT issues resolution on beneficial ownership of entities
On 25 September 2019, the Peruvian Tax Administration (SUNAT) has issued Resolution No. 185-2019/SUNAT establishing the procedure, deadlines and conditions for submitting the ultimate beneficiary informative return of entities. Effective from 1
See MoreCosta Rica publishes a resolution on the list of non-cooperative jurisdictions for tax purposes
On 25 September 2019, the Costa Rican Ministry of Finance published a resolution No. DGT-R-55-2019 on the list of non-cooperative jurisdictions for tax purposes. The list includes Bosnia and Herzegovina, Cuba, Eritrea, French Polynesia, Guadeloupe,
See MorePeru: SUNAT publishes report on GAAR
On 17 September 2019, the Peruvian Tax Administration (SUNAT) published Report No. 116-2019-SUNAT / 7T000 of 27 August 2019 on its website, through which SUNAT clarifies the application of General Anti-Avoidance Rule (GAAR). On 19 July 2012,
See MoreUruguay ratifies BEPS multilateral instrument
On 18 September 2019, Mr. Tabaré Vázquez, the president of Uruguay signed the law for the ratification of the multilateral convention to implement Double Taxation Agreement (DTA) related measures to prevent Base Erosion and Profit Shifting
See MoreUS: IRS publishes final and proposed regulations on new 100% depreciation
On 13 September 2019, the Treasury Department and the Internal Revenue Service published final regulations and additional proposed regulations under section 168(k) of the Internal Revenue Code on the new 100% additional first year depreciation
See MoreDominican Republic: Public Finance Ministry presents annual budget policy 2020
On 10 September 2019, the Ministry of Public Finance presented an annual budgetary proposal for the year 2020 and sent it to the Executive Branch to take it into account for the annual budget. It covers financial activities, excise duty on alcohol
See MoreArgentina: AFIP issues new General Resolution 4579/2019 for surcharge on import of goods
On 17 September 2019, the General Resolution 4579 was published in the Official Gazette, amending General Resolution 2281 in order to eliminate the different perception income tax rate on the definitive importation targets for consumption. This
See MoreCanada 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
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