Japan: Tax treatment of income from U.S. limited partnerships is treated as fiscally transparent entity
On 9 February 2017, Japan’s National Tax Agency (NTA) released a report on its website confirming that a US limited partnership (US LP) is treated as fiscally transparent for Japanese tax purposes when applying the US-Japan Income Tax Treaty. The
See MoreBolivia: Amendments in customs duties
Supreme Decree 3069 was published in the Official Gazette on 1 February 2017. The Decree changes the customs duties charged on imports of electronic equipment, image and sound recording, centrifugal dryers, vacuum cleaners, monitors and projectors,
See MoreChile: Tax Administration replies first query regarding GAAR
The Tax Administration has released Administrative Jurisprudence No. 261/2017 on 3rd February 2017 on its website. This addresses for the first time a query regarding the application or non-application of the general anti-avoidance rule (GAAR)
See MoreBrazil: MOF issues new threshold for automatic appeals
The Ministry of Finance (MOF) released a regulation 63/2017 (Portaria 63/2017) in the official journal on 10 February 2017. This has increased the threshold of BRL 2.5 million (previously, BRL 1 million) for automatic complaints (recurso de ofício)
See MoreTIEA between Chile and Uruguay enters into force
The Exchange of Information Agreement of 2014 between Chile and Uruguay entered into force on 4th August 2016 regarding tax matters and generally applies from 4 August 2016. The announcement of the entry into force of the agreement was published in
See MoreColombia updates tax obligations for self-withholding agents
The Colombian National Tax Authority (DIAN) recently issued a press release regarding new tax obligations applicable to self-withholding agents as from 1 January 2017. It recalls that the tax reform revoked the fairness tax so self-withholding
See MorePuerto Rico clarifies withholding tax on payments for services rendered
The Department of Treasury issued Bulletin 17-02 on 3 February 2017 regarding payments received for services. These payments for services are subject to the withholding of sales and use tax at a rate of 7%. The provisions are effective immediately
See MoreSaudi Arabia-Intergovernmental agreement to implement FATCA approved
The cabinet of Saudi Arabia officially approved the Intergovernmental Agreement (IGA) between Saudi Arabia (KSA) and the United States (US) on 6 February 2017. The agreement would improve international tax compliance and implement the Foreign
See MoreColombia: Tax reform 2016 and Transfer Pricing Updates
In accordance with law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016, introduces the following main changes to the transfer pricing regime. According to article 260-3 of the Tax Code (TC), as amended by the tax
See MorePanama ratifies DTA with Vietnam
On 7 February 2017, Panama ratified the Double Taxation Agreement (DTA) with Vietnam for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on
See MoreTIEA between Japan and Panama expected to be entered into force
On 12 March 2017, the Tax Information Exchange Agreement (TIEA) between Japan and Panama will enter into force. For criminal tax matters, the agreement generally applies from 12 March 2017 and for all other tax matters from 1 January 2013. This
See MoreUS: IRS releases its ‘dirty dozen’ list of tax scams for 2017
The Internal Revenue Service yesterday warned taxpayers to be alert to unscrupulous tax return preparers touting inflated tax refunds. This scam remains on the annual list of tax scams known as the “Dirty Dozen” for 2017. The “Dirty
See MoreColombia introduces new incentives for small enterprises
According to law 1819 of 2016, adopting the structural tax reform bill introduces amendments to the corporate income tax incentives applicable to small enterprises benefiting from Law 1429 of 2010, as follows: Years of incorporation Current
See MoreColombia: Fail to collect VAT is subject to a prison sentence between 48 to 108 months
The Colombian National Tax Authority (DIAN) issued a Press Release regarding the criminal offence introduced by Law 1819 of 2016 in the case of not collecting VAT and consumption tax, on 6 February 2017. In accordance with Press Release, as of 1
See MorePanama adopts fiscal transparency compliance policy
On 2 February 2017, According to Executive Decree 10, Panama's fiscal transparency compliance policy is adopted that was issued by the President and published in the Official Gazette. It includes joining the OECD Automatic Exchange of Information
See MoreColombia: Taxpayers can adjust the value of their fixed assets to 7.08%
On 30 December 2016, the Colombian National Tax Authority (DIAN) published a Decree 2202 of 2016 that regulates articles 70 and 73 of the Tax Code (TC) related to fixed asset value adjustments and the determination of taxable income or capital gains
See MoreUS: FATCA agreement signed with Ukraine
An intergovernmental agreement between Ukraine and the United States was signed on 7 February 2017 to improve international tax compliance with respect to the US Foreign Account Tax Compliance Act (FATCA). The agreement helps to reduce the
See MoreCanada: CbC report form published
A form entitled ‘RC 4649’ and instructions for completing the country-by-country (CbC) report has been published on 3rd February 2017 by the Canada Revenue Agency (CRA) for reporting the income allocation, tax allocation and business activities
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