Colombia publishes newly proposed TP regulations
Tax Authorities of Colombia (DIAN) published a proposed transfer pricing (TP) regulations to execute the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Action 13 and to establish the
See MoreCanada: CRA delays implementation of advantage rules
The Canada Revenue Agency (CRA) announced that the proposed implementation date for applying the advantage tax rules to investment management fees will be delayed until January 1, 2019. The rule could tax investment management fees paid outside of
See MoreUS: IRS invites public to comments on treatment of compensatory stock options
The Internal Revenue Service (IRS), as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to comments on the existing final regulations (TD 9088) dealing with the treatment
See MoreArgentina: AFIP announces a new portal for taxpayers
The Federal Public Revenue Administration (AFIP) launched a new portal service, in which taxpayer will find information about the fiscal situation and the personal data related to the agency. In order to access this portal, people have to enter with
See MoreUS: IRS appeals its tax court loss in the amazon transfer pricing case
On 29 September 2017, the Internal Revenue Service filed an appeal against March Tax Court ruling concerning Amazon’s cost-sharing agreement buy-in payment. The case is important because it is expected to provide fundamental guidance on the
See MoreU.S. signs agreements on the exchange of CbC reports with five countries
According to an IRS announcement on its website, it has signed separate agreements with the Czech Republic, Finland, Greece, Italy, and Sweden to exchange country-by-country reports on multinationals. Country-by-Country reporting data will be
See MoreCanada: CETA Trade Agreement enters into force
The Comprehensive Economic and Trade Agreement (CETA) between Canada and European Union came into force on September 21, 2017. The CETA is a progressive free trade agreement that covers virtually all sectors and aspects of Canada-EU trade in order
See MoreUS: IRS issues guidance for tax credit for expanding research activities
The Internal Revenue Service has issued guidance to Large Business & International (LB&I) Division examiners regarding the examination of the credit for increasing research activities under IRC Section 41 (“Research Credit”) claimed by
See MoreUAE: DTA signs with Costa Rica
The Minister of Foreign Affairs and Worship in Costa Rica, Manuel A. Gonzalez Sanz, has made a visit to attend a meeting at the ministry in capital San Jose and to meet with Assistant Minister of Foreign Affairs and International Cooperation for
See MoreUnited States: IRS issues draft advance pricing agreement (APA) template for public comment
The US Internal Revenue Service (IRS) has recently published on its web page that the IRS’s Advance Pricing and Mutual Agreement Program (APMA) is soliciting comments on a proposed revision to the template for advance pricing agreements (APAs).
See MoreUnited States: ADD/CVD Roundup for September 2017
Following table shows the Federal Register notices related to ADD/CVD cases for September 2017 in United States. Country Product Investigations Case Number Details Argentina Biodiesel Scheduling of the Final Phase of Antidumping Duty
See MorePGA Highlights: September 2017
In the United States the following events have taken place under the several PGA during the month of September 2017. Agencies Summary Federal Register Delay of transition of test program: This notice announces that from December 9, 2017, ACE
See MoreDominican Republic: DGII publishes the sixth version of the transfer pricing information
Recently, the Dominican Republic Tax Authorities (DGII) published the 6th version of the transfer pricing information return (DIOR) through its virtual platform. The content of the form has been simplified to guarantee the accuracy and organization
See MoreUS: Donald Trump plans to reduce tax burden for corporations and individuals
President Donald Trump proposed on 27 September 2017 the biggest U.S. tax overhaul in three decades. The proposals come in a “framework” for tax reform with the following changes. Individual measures: Seven existing tax brackets collapsed to
See MoreUruguay: Regulations on common reporting standard (CRS) issued
On 25 September 2017, the Tax Authority issued Resolution No. 6.396/017 providing instructions to financial institutions for reporting information under the Common Reporting Standard (CRS) guided by OECD. Under the CRS, Financial institutions are
See MoreArgentina: General Resolution 4130-E publishes in Official Gazette
The Federal Tax Administration (FTA), on September 20, 2017, published the General Resolution 4130-E in the Official Gazette. It establishes the country-by-country (CbC) guiding framework in Argentina and is applicable to ultimate parent entities of
See MoreNicaragua: Transfer pricing legislations are in effect as of 30 June 2017
The transfer pricing rules are in effect as of 30 June 2017 which was enacted by the Nicaraguan Congress through Law No. 822 of 2012. Law No. 822, enacted on 12 December 2012, contains the Nicaraguan transfer pricing rules that were intended to
See MoreDTA between Belarus and Ecuador enters into force
On 16 August 2017, the Double Taxation Agreement (DTA) between Belarus and Ecuador was entered into force and it will apply from 1 January 2018. On 25 September 2017, Ministry of Taxes and Levies of Belarus announced it in their website. The
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