Peru: 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
See MoreArgentina: Resolution for benefits under mining regime
On 4 February 2019, Argentina published Resolution 6/2019 of 31 January 2019 in the Official Gazette, which establishes a special promotion regime for the development of the mining activity in the Argentine territory provided by Law No. 24,196. The
See MorePeru: Tax authority clarifies the scope of CFC rules
On 7 February 2019, the Peruvian Tax Authority published a report (097-2018-SUNAT / 7T00000) clarifying the passive net income attribution of CFC rules to its Peruvian shareholders. The Ministry of Finance simplifies the following issues in the
See MoreDominican Republic: DGII updates transfer pricing brochure
On 7 February 2019, The Dominican Republic’s Directorate General of Internal Revenue (DGII) published online brochure to update guidance on transfer pricing. The brochure makes a number of following changes on transfer pricing: Reporting
See MoreColombia: DIAN publishes transfer pricing return and other forms for 2019
On 15 January 2019, Directorate of Taxes and National Customs (DIAN) of Colombia published Administrative Regulation 000004 of 2019 to provide the following form for filing a 2019 tax return: Informative transfer pricing return (Form 120);
See MoreBrazil: RFB updates TP rules on import transaction and commodities
On 29 January 2019, the Brazilian Federal Revenue Department (RFB) issued Normative Instruction (NI) 1870/2019 amending NI 1312/2012 effective as of calendar year 2019. The amendments are mainly related to import transaction and commodities and some
See MoreArgentina releases decree regarding tax reform measures for corporations
On 27 December 2018, Argentina published a Regulatory Decree 1170/2018 in the Official Journal, which entered into force on 28 December 2018. The decree prescribes policy changes to Law 27,430 of 2017, which introduced tax reform measures for 2018.
See MorePanama sign MCAA for the exchange of CbC reporting
On 24 January 2019, the tax authority of Panama signed the Multilateral Competent Agreement (MCAA) for the exchange of Country-by-Country (CbC) reports. The purpose of the CbC MCAA is to set forth rules and procedures as may be necessary for
See MoreChile: IRS clarifies Taxation of Dividends and Interest
Recently, the Internal Revenue Service (IRS) issued two separate Rulings 59 and 2546 to clarify the taxation of dividends and interest by resident and nonresident taxpayer. The two rulings separately discussed in below: Taxation of dividends Ruling
See More