Peru publishes Resolution on filing Tax Return for 2018
The Peru tax authority (SUNAT) has issued Resolution No. 015-2019/SUNAT, concerning the filing of both individual and corporate tax returns for the 2018 tax year, including the filing deadlines. The deadlines are set from 25 March to 5 April 2019,
See MoreDominican Republic: DGII issues transfer pricing documentation thresholds for 2019
On 17 January 2018, Directorate General of Internal Revenue (DGII) published the Transfer pricing (TP) reporting threshold for 2019. The DGII has issued Notice 8-19, which prescribes related party transaction threshold for transfer pricing reporting
See MorePuerto Rico enacts the tax reform law
On 10 December 2018, Puerto Rico enacted Bill No. 1544 as Law No. 257 of 10 December 2018. The law includes numerous amendments to the Puerto Rico Internal Revenue Code of 2011 (PR Code). The changes are to generally apply for periods beginning
See MorePanama publishes law containing transfer pricing rules for preferential tax regimes
On 26 December 2018, Panama released the Law No.69 in the Official Gazette No.28684-B which sets out the method for calculating income earned from the “transfer or exploitation” of intellectual property assets. The law also includes provisions
See MoreColombia legislates the tax reform Bill for 2019
Colombia enacted tax reform (Law 1943-Tax Reform) on 28 December 2018. The Tax Reform makes numerous changes to the Colombian tax rules that generally apply from 1 January 2019. The tax reform includes following changes: Corporate tax: The Tax
See MoreUruguay: Tax authority revises list of low or no taxation countries and jurisdictions
On 17 December 2018, the tax authority of Uruguay published Resolution No. 10,730 revising the list of countries and jurisdictions with no or low taxation. The declared list of countries and jurisdictions are listed below: Andorra Falkland
See MoreColombia: Tax authority publishes decree regarding tax return and TP documentation deadline
On 27 December 2018, the Colombian Tax Administration (DIAN) has published Decree No.2442 specifying the deadlines for filing and payment of the tax return (declaration) for 2019 and the deadline for transfer pricing documentation, including
See MoreUruguay updates CbC Reporting requirements
On 4 January 2019, Uruguay's Directorate General of Taxation (DGI) has issued Resolution No. 94/2019 regarding submission of Country-by-Country (CbC) reports and notifications. Uruguay's CbC reporting requirements apply fiscal years beginning on 1
See MorePeru releases decrees regarding deduction of expenses related to intra-group services
On 30 December 2018, the Peruvian Minister for Economic Affairs issued Supreme Decree 337-2018-EF and Supreme Decree 339-2018-EF, which contains provisions on the deduction of expenses for intra-group services and the definition of
See MoreArgentina enacts regulation to implement the tax reform
On 4 December 2018, Argentina enacted Law 27,430 (the Act), which contains proposals for the implementation of the tax reform. The law introduced the taxation of indirect transfers of assets located in the country, pointing out that transfers within
See MorePuerto Rico: Governor sign the law of tax reform bill
On 10 December 2018, Puerto Rico Governor Ricardo Rosselló signed into law Bill No. 1544 as Law No. 257 of 10 December 2018. Under the reform bill, the regular corporate tax rate has been reduced from 20% to 18.5% starting from taxable year after
See MoreCosta Rica passes tax reform bill
On 4 December 2018, Costa Rica passed a tax reform bill which includes several tax reform measures. Interest limitation rule: Under the law, an interest limitation rule applies which interest expenses that exceed 20% of the taxpayer's
See MoreMexico: SAT publishes the Miscellaneous Fiscal Resolution for 2018
On 30 November 2018, the Tax Administration Service (SAT) published in its portal the "Fourth of Modifications to the Miscellaneous Fiscal Resolution for 2018" and its annexes. Modifications to the value of operations with related parties within the
See MoreMexico publishes the Fourth Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2018
On 30 November 2018, the Fourth Resolution of Modifications to the Miscellaneous Fiscal Resolution for 2018 and Annexes 1, 1-A, 3, 7, 11 and 23 were published in the Official Gazette. Among others the modification added as a criterion in terms of
See MoreBrazil: Revenue Authority publishes new Normative Instruction regarding MAP
On November 29, 2018, the Revenue Authority published Normative Instruction No. 1846 of 28 November 2018 that covers the rules for submitting a Mutual Agreement Procedure (MAP) request, the approval of a request, and the termination process. It
See MoreBrazil: Tax tribunal publishes a decision on costs included for resale price method
On November 20, 2018, the Administrative Tribunal for Federal Tax Cases (CARF) has published Decision 1402003338 of 14 August 2018. This decision states that all the expenses regarding freight, insurance, and customs need to include when allowed by
See MoreUS: IRS announces priority guidance plans addressing many new international tax issues
On 8 November 2018, the US Treasury and IRS published its 2018–2019 Priority Guidance Plan, detailing tax guidance the government intends to focus its effort on in the coming months. The Guidance Priority List focuses resources on guidance items
See MoreSingapore signs TIEA and FATCA with the US
On 13 November 2018, the Inland Revenue Authority of Singapore has confirmed the signing of a tax information exchange agreement (TIEA) and a reciprocal FATCA Intergovernmental agreement (FATCA IGA) with the United States. The TIEA will permit
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