Argentina: New investment regime for the oil and gas industry
The Executive power of Argentina issued Decree N° 929/2013 to encourage investments in the oil and gas regime through new system. The Decree was published in the Official Gazette on July 15, 2013. According to the Decree eligible entities of the
See MorePeru: Changes to transfer pricing documentation requirements
The Resolution 175-2013 of Peru sets out regulations concerning new transfer pricing documentation requirements which have become effective from 1 June 2013. According to the new rule taxpayers subject to the transfer pricing rules are required to
See MoreCanada: Extended CIT return deadline
Businesses in parts of Canada including Alberta have recently been affected by extreme weather conditions. This has caused damage to premises and delays in completing administrative tasks. In response to this problem the Canada Revenue Agency (CRA)
See MoreColombia and Mexico DTA will enter into force on 11 July 2013
The Income and Capital Tax Treaty between Colombia and Mexico will enter into force on 11 July 2013. The treaty will be applicable in Mexico from 1 January 2014 and in Colombia from 1 January 2014 for income tax matters and from 11 July 2013 for
See MoreDTA between Ecuador and Singapore signed
Singapore and Ecuador signed an Agreement for the Avoidance of Double Taxation (DTA) on 27 June 2013. The provisions of the treaty will have effect from 1 January of the calendar year next following that in which the agreement enters into
See MoreCanada: Extra GST/HST return for large businesses
Certain large businesses, in addition to filing their regular GST/HST returns will have to face an extra GST/HST (goods and services tax / harmonized sales tax) filing requirement on June 30, 2013. Employers offering registered pension plans to
See MoreArgentina: New process for determining “tax haven” jurisdictions
Argentina’s tax authority (AFIP) has issued a decree introducing new criteria for when to consider countries as “tax haven” jurisdictions for transfer pricing purposes. This Decree was published on May 30, 2013. The Decree states that the AFIP
See MoreBrazil: Increase in revenue limit to opt for presumed profit method
The government of Brazil has again increased the gross income limit for companies to opt for taxation under the presumed profit regime. Companies electing to use the presumed profit method are taxed on a statutory rate applied to their gross
See MoreCanada – Tax-related interest rates for 2014
It was announced by the Canada Revenue Agency (CRA) that tax-related interest rates for taxable credits and for tax overpayment and underpayments for the third quarter of 2013 (July 1- September 30) will remain unchanged for this year and the rates
See MoreUnited States: IRS publishes quarterly list of individuals who have expatriated
The US Internal Revenue Service (IRS) has published a quarterly notice with a list of US citizens and long-term US residents who have renounced their citizenship or residency for US federal tax purposes. The Notice is required under section 6039G
See MoreCanada: Reforming Temporary Foreign Worker program
Currently, Canadians have raised concerns about the Temporary Foreign Worker Program. A review of the Temporary Foreign Worker Program has been incorporated in the Economic Action Plan 2013 and legislation has been enacted to change the rules. It
See MoreBrazil: Expands Threshold for Companies for presumed Profit Method
The profit method is one of four calculation regimes that may be applied by some companies for the computation of profits for Brazil’s corporate income tax. This is a simplified regime that enables a company to pay tax based on a percentage of its
See MoreBrazil: Tax subtraction from donations and sponsorships
Decree No. 7,988/2013 was published in the Official Gazette of 18 April 2013 and in force as of that date. Individuals and legal entities under the actual profit regime can deduct sponsorships and donations made to the National Program for
See MoreColombia: Proposed Regulations for Bank Debit Tax
The Colombian Government is currently preparing a Decree, which will regulate the provisions of bank debit tax. This bank debit tax was introduced by Law 1607 of 2012. This proposed Decree will provide for exemptions and the refund of the bank debit
See MoreHungary: Proposed Changes to Transfer Pricing Rules
The Ministry of National Economy (’the Ministry’) of Hungary has proposed changes to Hungarian transfer pricing documentation requirements. They have introduced provisions relating to low value added services and specified criteria for selection
See MoreUS: Public comments requested on branch profits tax for foreign corporations
The US Treasury Department and the Internal Revenue Service (IRS) are requesting comments concerning regulations TD 8223 (Branch Tax), TD 8432 (Branch Profits Tax) and TD 8657 (Regulations on Effectively Connected Income and the Branch Profits
See MoreMexico: Mining royalty plan
A proposal to levy a new royalty tax on mining profits in Mexico, the world’s largest producer of silver, passed a congressional committee on 16 April 2013. The proposal would also increase penalties for mining concessions that have not been
See MoreArgentina –Modifications to the transfer pricing regulations through General Resolution N° 3,476
The Argentine Federal Tax Authorities issued General Resolution N° 3,476 on 10 April 2013. The Resolution has revised the transfer pricing compliance rules and introduced modifications to the current Transfer Pricing regulations. General Resolution
See More