US: 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
See MoreCanada: Finance Department publishes draft Budget proposals for public comments
On 30 July 2019, the Finance Department published draft Budget proposals inviting comments to implement some of the remaining measures from the 2019 budget. The deadline for public comments is 7 October
See MoreEcuador introduces TP risk model
On 1 August 2019, the Inter-America Center of Tax Administration (CIAT) publishes a document on Ecuador Transfer Pricing (TP) Risk Model in its official website. The SRI of Ecuador, with the coordinated support of CIAT, the United Nations (UN), the
See MoreCosta Rica: MOF publishes draft resolution on advance pricing agreements (APA)
On 2 July 2019, the Ministry of Finance released a draft resolution providing rules on advance pricing agreements (APA) under the OECD transfer pricing guidelines. The resolution outlined the application procedures for approval, refusal, renewal
See MoreCosta Rica: Tax authority issues guidance on transfer pricing rules
On 26 June 2019, Costa Rican tax authority published the Resolution N° 41818-H in the Official Gazette that changes Income Tax Law regulation including transfer pricing obligations. The new Regulation defines persons as related persons who are
See MoreArgentina: AFIP updates resolution on advance payment of tax
On 12 July 2019, the Federal Administration of Public Revenues (AFIP) of Argentina has published General Resolution No. 4522/2019 amending several provisions of General Resolution 4034 which was issued in 2017. The resolution modifies the
See MoreColombia publishes new thin capitalization rule
On 26 June 2019, the Government of Colombia published a Decree 1146 of 2019, concerning the new thin capitalization rules which amended the previous law 1943 of 2018. The new Decree 1146 of 2019 includes the following measures: The thin
See MoreEcuador: SRI issues decree on advance income tax payments
On 5 July 2019, the Ecuadorian Internal Revenue Service (Servicio de Rentas Internas-SRI) issued Executive Decree No. 806 of 25 June 2019 in its official website. The decree introduces new schedule for advance income tax payments. The payment of
See MoreBrazil updates its blacklist removing San Marino
On 28 June 2019, The Department of Federal Revenue (RFB) of Brazil has published Normative Instructions No. 1896 of 27 June 2019 in the official gazette amending Normative Instructions Nº 1037. Through the instruction RFB removes San Marino from
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