Peru: SUNAT extends deadline for submission of CbC report to March 2019
On 11 November 2018, Peruvian tax authorities (SUNAT) published Ruling No. 264-2018 SUNAT which extended the due date for submitting CbC report from November 2018 to March 2019 for fiscal year 2017. The extension applies to Peruvian taxpayers who
See MoreArgentina: Taxpayers wait for enactment of draft decree no. 1112/2017
Government has released a draft decree No.1112/2017 for tax reform Law 27430 on December 29, 2017, but it has not officially published yet. This decree includes transfer pricing aspects, permanent establishment (PE) rules, restriction on interest
See MoreOECD: Latin America Academy for Tax and Financial Crime Investigation Begins Courses
On 16 November 2018 the OECD announced that the Latin America Academy for Tax and Financial Crime Investigation has launched its first programme. Tax investigators from Argentina, Bolivia, Chile, Colombia, Mexico, Paraguay, Peru and Dominican
See MoreArgentina: General Resolution 4332/2018 publishes regarding CbC reporting requirements
The Federal Administration of Public Revenues (AFIP) has published General Resolution 4332 of 8 November 2018, which includes several amendments to General Resolution 4130 regarding Country-by-Country (CbC) reporting. It enters into force from
See MorePanama: MHQ companies are subject to transfer pricing regulations
Law No. 57 was published on October 24, 2018 in the Official Gazette, which amends the multinational headquarters regime (MHQ regime). It contains provisions on applying transfer pricing regulations to transactions conducted by entities with an MHQ
See MoreBrazil: Tax Authority proposes Ordinance for corporate taxpayer classification
In accordance with the compliance efforts of Organization for Economic Co-operation and Development (OECD), tax authorities proposed an Ordinance regarding corporate taxpayer classification. The tax authorities need to analyze the capability of the
See MoreArgentina: AFIP publishes information regarding CbC reporting
On October 24, 2018, the tax authority (AFIP) published information regarding Country-by-Country (CbC) reporting in their website. Two information regimes are implemented in order to combat tax evasion and avoidance and the transfer of benefits to
See MoreIsrael deposits its MLI Ratification Instrument
The Organization for Economic Co-operation and Development (OECD) announced on September 13, 2018 that Israel deposited its instrument of ratification to implement the Multilateral Convention to Implement Tax Treaty Related Measures for preventing
See MoreDominican Republic joins BEPS inclusive framework
On 8 October 2018, the OECD announced that The Dominican Republic joined the Inclusive Framework on BEPS. As a member of the Inclusive Framework on BEPS, Dominican Republic will monitor implementation of the following four BEPS minimum standards:
See MoreEl Salvador: DGII updates transfer pricing information return and guidelines
On 1 October 2018, the Tax Authority (General Office of Internal Revenue ) updated the new version of the “Report on Operations with Related Parties (Form F-982v4),” whose method of filing is now changed from manual filing to online filing and
See MorePeru introduces GAAR, new thin capitalization rule, definition of PE, and Other Changes
On 13 September 2018, the Peruvian government has published Legislative Decree No. 1422 and Legislative Decree No. 1424, which include measures for the implementation of the General Anti-Avoidance Rule (GAAR), new thin capitalization and interest
See MoreUS: IRS proposes to withdraw section 385 documentation regulations
On 21 September 2018, IRS published a document proposing to remove Section 385 from treasury regulation that was finalized in the last of the 2016. The regulations require multinationals that issue related-party debt to provide information to the
See MoreUS: IRS issues reminders relating to Form 8975 of CbC reporting
On 18 September 2018, IRS published a release reminding MNE groups on the processes of filing country-by-country reports on Form 8975. Reminder to U.S. MNEs Filing Form 8975 with no U.S. Schedule A (Form 8975) When submitting Form 8975 and Schedules
See MorePeru: Added new thin Capitalization Rules and Amended Income Tax Law
Peru’s President enacted Legislative Decree 1424 on 13 September 2018, which amends the income tax law with regard to the thin capitalization rules, the indirect transfer of shares, the definition of permanent establishment (PE) and the indirect
See MoreUS: IRS publishes draft form regarding the “base erosion and anti-abuse tax” (BEAT)
On 5 September 2018, the United States (US) Treasury and the Internal Revenue Service (IRS) released a draft of Form 8991 concerning the “base erosion and anti-abuse tax” (BEAT) reporting for 2018. In an effort to " level the playing field
See MoreBrazil: Administrative Council of Tax Appeals approves validity of resale price method (PRL 60)
The Administrative Council of Tax Appeals (CARF) issued binding decision 115 (Súmula no. 115) on 11 September 2018. The new decision approving that, the calculation method of the ' 60% Profit Price Less Profit Method (PRL 60)' provided for in
See MoreMexico: Tax authority updates the transfer pricing adjustment rules
Recently, the Mexican tax authorities issued the Second Resolution of modifications to the 2018 Miscellaneous Tax Resolution (MTR) in which the rules regarding transfer pricing adjustments were amended and certain additional provisions were
See MoreBrazil: RFB clarifies Transfer pricing rules on import of products
On 30 august 2018, the Department of Federal Revenue of Brazil (RFB) published a ‘Private Ruling 95/2018’ in the Official Gazette which clarifies the calculation of price parameter on import of steel product for resale. Under this Private Ruling
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