United States – IRS releases transfer pricing audit “roadmap”
The IRS Large Business & International (LB&I) division has released a transfer pricing audit "roadmap" that is intended to be a practical, user-friendly toolkit organized around a notional 24-month audit time-line. The roadmap has been
See MorePeru approves tax treaties
The income tax treaties of Peru with Korea, Mexico, Portugal, and Switzerland recently obtained approval by the Peruvian Congress. The notices were published in the Official Gazette. Under the new treaties, relief for taxes withheld at source
See MoreCanada: FTA with Israel is under negotiation
A first round of negotiations for a Free Trade Agreement (FTA) between Canada and Israel was held from 3 to 9 February 2014, in
See MoreIGA agreement sign between Hungary and US to implement FATCA
On February 4, 2014, Hungary and the US signed an agreement to implement the U.S. Foreign Account Tax Compliance Act
See MoreChile changes foreign tax credit system
On 31 January 2014, the Chilean government published in the official Gazette Law 20.727, which makes changes to the country’s foreign tax credit (FTC) rules. The FTC amendments increase the availability of FTCs for indirectly owned foreign
See MoreBhutan approves a law to ratify the DTA signed with India
On February 6, 2014, Bhutan's National Council approved a law to ratify the Double Taxation Avoidance Agreement (DTA) signed with India. The DTA will provide tax stability to the residents of India and Bhutan and facilitate mutual economic
See MoreBahrain ratifies its TIEA with Canada
An Agreement between Canada and Bahrain for the exchange of information on tax matters which was signed on June 4, 2013 it was ratified by Bahrain on February 4, 2014. The Agreement provides for the mutual exchange of tax information that is
See MorePeru – Resolution changes withholding rate for VAT
On 1 February 2014 Peru’s tax administration issued a resolution concerning changes to the withholding rate for value added tax (VAT). This rate applies to the supplier, who must withhold the tax in respect of a transaction that is liable for VAT.
See MoreBrazil – Tax authority revises position on cross-border reimbursement arrangements
Brazil’s tax authority has issued a ruling to a taxpayer reflecting a change of position concerning cross-border cost reimbursement arrangements. Traditionally, the tax authority (Receita Federal do Brazil—RFB) has imposed a high tax burden of
See MoreBrazil – Ruling permits taxpayers to align their transfer pricing policies
According to a recent ruling by the Brazilian tax authority taxpayers should be able to better align their transfer pricing policies to eliminate potential contingent liabilities, reduce taxable adjustments, and/or eliminate the double taxation
See MoreUS: Senate democrat leader opposes Trade Promotion Authority renewal
The US Senate Majority Leader has expressed his opposition to the Trade Promotion Authority (TPA), despite the intention of President Obama to engage with Congress to pass the legislation providing for the renewal of the TPA. This opposition to the
See MoreUS: Republican Obama Care Abolition Plan Includes New Tax Credit
The recent healthcare reforms of the Affordable Care Act, known colloquially as Obama care, have been vehemently opposed by some sections of the US Congress. Three United States senators have now released a legislative outline of how the Republican
See MoreUS: publication on foreign tax credit for individuals
The US Internal Revenue Service (IRS) has released the 2014 revision of Publication 514 (Foreign Tax Credit for Individuals). The publication of 24 January 2014 is intended for use in preparing 2013 tax returns. Publication 514 explains the
See MoreUS: Internal Revenue Service (IRS) opens 2014 Tax Season
The US Internal Revenue Service (IRS) opened the 2014 United States filing season for individuals on January 31, highlighted a growing selection of online services, and encouraged taxpayers to check out a variety of tax benefits, such as the Earned
See MoreUS: Case Made For Progressive Consumed Income Tax
In a recent editorial article the President and CEO of the American Council for Capital Formation called for consideration to be given to a change from the current income tax code to a "progressive consumed income tax" in the United States. He
See MoreUS: Public comments requested on withholding certificates for foreign persons
The US Internal Revenue Service (IRS) and the US Treasury Department have issued a notice requesting comments on various IRS forms that are used as withholding certificates for foreign persons (i.e. certificates to claim reduced or zero withholding
See MoreUS agrees to tax talks with India under mutual agreement procedure
Following an approach by India the US tax authorities for finding a solution to tax cases of about 100 US companies that have opted for the Mutual Agreement Procedure (MAP), the US has now agreed for a meeting next month to discuss MAP, advance
See MoreTIEA between Canada and Liechtenstein entered into force
The Agreement between Canada and Liechtenstein for the Exchange of Information on Tax Matters entered into force on January 26, 2014. The Agreement was signed on January 13, 2013. The Agreement has effect in accordance with the provisions of
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