US: Report on advance pricing agreements
The US report on advance pricing agreements issued on 25 March 2013 covers the activities of the program in 2012. At the beginning of 2012 the APA program was merged with the office of the competent authority (USCA) that is responsible for the
See MoreColombia: Introduces Corporate Tax Reforms
The Colombian Government has introduced measures relating to corporate tax changes. For the purposes of corporate tax, it redefined the concept of permanent establishment. Corporate income tax rate for companies and for non-resident companies
See MoreCanada – 2013 budget announcements
The Canadian budget proposals for 2013 were announced on March 21, 2013. The proposals include measures to combat tax evasion and to provide some help for companies in the manufacturing and mining sectors. There is no change to the corporate tax
See MoreUS: IRS invites public comments on Bilateral Safe Harbors for Certain Transfer Pricing Issues
The Internal Revenue Service (IRS) announced on March 15, 2013, that it is consulting interested parties on the development of a model memorandum of understanding (MOU) between Competent Authorities relating to transfer pricing safe harbors for
See MoreUS: IRS Announces Interest Rates on tax overpayments and underpayments for 2013 second quarter.
The US Internal Revenue Service has issued Revenue Ruling 2013-6 with the announcement of the interest rates on tax overpayments and tax underpayments for the calendar quarter beginning 1 April 2013. The rate will remain the same as in the previous
See MoreChile: Issuance of Resolution No. 14 of 2013
Resolution No. 14 of 2013 has been issued by the Chilean Internal Revenue Service (Chilean IRS) that contains the new Transfer Pricing Annual Informative Return for calendar year 2012 and the proper completing instructions. The deadline for filing
See MoreUnited States: IRS publishes quarterly list of individuals who have expatriated.
The US Internal Revenue Service 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 dated 29 January 2013, and is based
See MoreTreaty between Finland and Uruguay enters into force
The Income and Capital Tax Treaty between Finland and Uruguay entered into force on 6 February 2013. The treaty generally applies from 1 January 2014. The treaty is based generally on the model tax conventions of the OECD and UN. The definition of a
See MoreChile: New Transfer Pricing Compliance Requirement
A new transfer pricing compliance requirement has been introduced in Chile by Resolution No. 14 of 2013. According to the new rule Chilean taxpayers are required to file a Transfer Pricing Annual Informative Return (‘TP Return’) for calendar
See MoreLatvia –Mexico: Treaty enter into force
The treaty between Latvia and Mexico for the avoidance of double taxation which was signed on 20 April 2012 is to enter into force on 2 March 2013. The maximum withholding tax on dividends is 10%, reduced to 5% where the recipient company is the
See MoreEcuador: New transfer pricing reporting requirements
The Internal Revenue Service of Ecuador published Resolution NAC-DGERCGC13-00011 on 24 January 2013. Resolution NAC-DGERCGC13-00011 modifies Resolution NAC-DGER2008-0464 on transfer pricing reporting requirements. According to Resolution
See MoreTreaty between Barbados and United Kingdom enters into force
The Double Taxation Agreement between Barbados and the United Kingdom entered into force on 19 December 2012 which was signed in Barbados on 26 April 2012. The Double Taxation Agreement generally follows the provisions of the OECD Model; however
See MoreColombian Tax Reform
The Colombian tax system is reformed by the Law No. 1607 of 2012 and it took effect from 2013. The major changes are as below: The reform introduces a new minimum tax (IMAN) that is a progressive flat tax based on the amount of income derived. The
See MoreBrazil: Withholding Tax Changes on Profit-Sharing Payments
Provisional Measure No 597 of December 26, 2012 came into effect on 1 January 2013.This introduces a new regime for the taxation of profit-sharing payments received by employees from their employers. The change permits employed persons to obtain up
See MorePeru and Portugal signed a DTA
Peru and Portugal signed an agreement on 19 November 2012 to avoid double taxation and prevent fiscal evasion. No further details of the agreement are currently
See MoreEcuador: Minimum monthly salary
The minimum monthly salary of Ecuador has been set to USD 318 by the Ministerial Decree 00215/2012 of the Minister of Labour, effective from 1 January 2013. The rate was previously USD
See MoreBrazil to increase monthly minimum salary
Brazil's government will raise the minimum monthly salary by 9% in 2013. The Official Gazette of 26 December 2012 published Decree 7,872/2012 introducing a new monthly minimum salary. The rate has increased to BRL 678 from BRL 622. This new rate is
See MoreMexico: Budget for 2013 has been approved
Congress has approved the Budget for 2013 and published in the Official Gazette on 13 December 2012. In new budget some changes has approved: The corporate income tax rate it will reduce to 29% as from 2014 but 4.9% income tax withholding rate will
See More