Mexico: The tax authority issues new rules regarding transfer pricing adjustments
On July 11, 2018 the Mexican Tax Authority (SAT) has published amendments to the rules for transfer pricing adjustments now included in rules 3.9.1.1-3.9.1.5 of Resolución Miscelánea Fiscal (RMF). These rules include the definition of transfer
See MorePeru enacts new tax legislation for a short period
Peru’s Congress enacted Law 30823 on 19 July 2018 granting President Power to enact new tax legislation for a short period on specific issues. The President has 60 calendar days till 17 September 2018 to issue new tax legislation. The issues are
See MorePuerto Rico publishes extended date for filing annual corporate reports for 2017
The Secretary of State published Administrative Order 2018-04 (AD 2018-04) on 16th July 2018, extending the due date from 18th July 2018 to 17th October 2018 for the filing of the 2017 annual corporate reports.This additional extension only applies
See MoreUruguay: Directorate General of Taxation amends R&D tax incentive regime
Recently, the Directorate General of Taxation has published Law No. 19.637 with numerous tax amendments. The major change incorporated in the area of incentive regime that provides an exemption for income derived from Research & Development
See MorePuerto Rico: Treasury Department defines extended timeline for filing returns 2017
The Treasury Department of Puerto Rico (PRTD) has explained (Informative Bulletin 18-14) the due dates for taxpayers who have submitted automatic renewal filings for filing income tax returns for 2017. Calendar year-end taxpayers who submitted an
See MoreUS: IRS issues new transfer pricing examination guide
On 29 June 2018, Treaty and Transfer Pricing Operations (TTPO) of the Large Business and International (LB&I) division of the IRS released the Transfer Pricing Examination Process (TPEP) for use in transfer pricing examinations. Transfer Pricing
See MoreCanada: CRA publishes 2017 APA Program Report
The Canada Revenue Agency (CRA) has published an annual report on its APA program since the 2001 to 2002 fiscal year. Since 2016, the annual report has been based on a calendar year, whereas the previous annual reports were based on a fiscal year.
See MoreCanada: NRA announces successful first round of CbC report exchanges
The Minister of National Revenue Agency (NRA) has announced that Canada has completed its first round of CbC report exchanges successfully. In this way, Canada has automatic access to more information and data that will allow the Canada Revenue
See MoreU.S. and Indonesia sign an agreement on the exchange of CbC reports
According to an IRS announcement on its website, the competent authorities of the U.S. and Indonesia have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
See MoreBrazil clarifies CFC rule regarding exemption for oil and natural gas industry
Private Ruling 4,020/2018 concerning the exemption under CFC rules for profits acquire by the oil and gas industry was published in the Official Gazette on 19th June 2018. The Decision clarifies that the tax exemption of the profits realized is
See MoreEcuador: SRI revises deadline to submit tax compliance report
The tax authority of Ecuador (SRI) issued a resolution to extend the deadline for filing the tax compliance report from 1 July 2018 to 28 July 2018, based on the ninth digit of tax identification
See MorePeru: Tax administration issues resolution regarding master file and CbC reporting requirements
The tax administration (Superintendencia Nacional de Administración Tributaria, SUNAT) issued Resolution 163-2018/SUNAT (the Resolution) on 29 June 2018 which was published in the Official Gazette. The Resolution sets out the rules for preparing
See MoreColombia updates late payment interest rate for July 2018
According to Administrative Regulation 0820 of 2018, the effective monthly interest rate for late payment of taxes has been set at 28.05% and valid from 1 to 31 July
See MorePeru: Tax administration clarifies the exchange rate applicable to capital gains arising from the transfer of shares
On 3 November 2017, the tax Administration in Peru issued report no. 039-2017-SUNAT/7T0000, clarifying the exchange rate applicable to capital gains arising from the transfer of shares. The report refers to a transaction as part of which a
See MoreBrazil: Government sanctioned guidance regarding new tax incentives for automotive sector
On 5th July 2018 government sanctioned guidance (Provisional Measure 843/18 (PM 843)) that initiates a new tax incentive program for the automotive sector. According to the program the following main tax incentives for a five-year period, which may
See MoreColombia: New resolution for CbC reporting
On 21 June 2018, the Colombian National Tax Authority (DIAN) issued a draft resolution concerning the obligation to notify country-by-country (CbC) reporting responsibilities. Resident taxpayers are required to file informative transfer pricing
See MorePGA Highlights: July 2018
In the United States the following events have taken place under the several PGA during the month of June 2018. Agencies Summary Federal Register Correction in advance notification of sunset review: This notice serves to correct the July 2018
See MoreUnited States: ADD/CVD Roundup for July 2018
Following table shows the Federal Register notices related to ADD/CVD cases for June 2018 in United States. Country Product Investigations Case Number Details Argentina Lemon Juice Suspended Investigation A-822-804 See the Federal Register
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