Canada: CRA issues MAP program report
The Canada Revenue Agency (CRA) issued the latest mutual agreement procedure (MAP) program report on April 13, 2018. The MAP program is a service provided by the CRA to assist taxpayers in resolving cases of double taxation or taxation not in
See MoreEl Salvador issues new Transfer Pricing Guidelines
On 21 March 2018, the General Directorate of Internal Taxes of the Ministry of Finance issued the Transfer Pricing Orientation Guide (DG-001/2018). These guideline is intended to help taxpayers to comply with the following legal obligations: The
See MoreUS: IRS publishes annual advance pricing agreement report for 2017
On 30 March 2018 with an announcement, IRS published Advance Pricing Agreement (APA) report for the calendar year 2017. The report describes the experience, structure, and activities of the APMA Program during calendar year 2017. It does not provide
See MoreUS: IRS publishes a notice concerning CbC reporting requirements of certain U.S. MNE groups
On 30 March 2018, IRS released an advance copy of Notice 2018-31 concerning national security considerations with respect to country-by-country (CbC) reporting. In consideration of the national security interests of the United States, the notice
See MoreCanada: Federal budget bill C-74 receives first reading
The Canadian federal government released first reading of Budget Implement Act (Bill C-74) on March 27, 2018. This bill includes measures from the 2018 federal budget and other measures including income tax amendments, such as, small business tax
See MoreUS: IRS issues additional guidance for computing the “transition tax” on foreign earnings
On 2 April 2018, the Treasury Department and the Internal Revenue Service published additional guidance (Notice 2018-26) for computing the “transition tax” on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax
See MoreChile: Tax authority issues Ordinances for describing dual corporate tax regimes
The tax authority has published Ordinance 470 and Ordinance 471 of 5 March 2018. It describes the application of the dual corporate tax regimes introduced as of January 1, 2017. These regimes are the standard attribution regime (AIS regime) and the
See MoreEl Salvador: Ministry of Finance publishes updated transfer pricing guidelines
On 21 March 2018, the Ministry of Finance has published the updated transfer pricing guidelines (DG-001/201). The guidelines outline the comparability analysis adjustments and adjustment information provided in the transfer pricing
See MoreUnited States: ADD/CVD Roundup for March 2018
Following table shows the Federal Register notices related to ADD/CVD cases for March 2018 in United States. Country Product Investigations Case Number Details Argentina Biodiesel Final Determination of Sales at Less Than Fair Value and Final
See MorePGA Highlights: March 2018
In the United States the following events have taken place under the several PGA during the month of March 2018. Agencies Summary CBP CBP releases E-Commerce Strategy: The U.S. Customs and Border Protection released its e-commerce strategy on
See MoreOECD: Revenue Statistics in Latin America and the Caribbean
On 27 March 2018 the OECD released the latest edition of the publication Revenue Statistics in Latin America and the Caribbean 2018. The publication notes that tax revenues in the region fell in 2016, with an average tax to GDP ratio of 22.7%, 0.3%
See MorePuerto Rico establishes the procedure for e-filing of the corporate tax return for 2017
The Treasury Department of Puerto Rico has issued guidance (Circular Letter (CL) 18-03) for the electronic filing (e-filing) of corporate income tax returns for tax year 2017. Procedure for electronically file required evidence with the corporation
See MoreCosta Rica: MOF increases the interest rate for late payments and refunds
On 16 March 2018, the Ministry of Finance (MoF) has increased the interest rate for late payments and refunds of overpayments from 12.8% to 13.73%. The rate is effective from 1 April
See MoreArgentina: Deadline extends for providing incentive benefit
Argentina has published Decree 229/2018 of 16 March 2018 in the Official Gazette. It effects from January 1, 2018. Under Decree 379/2001, this decree changes and extends the effective date for providing incentive up to December 31, 2018. This
See MoreCanada: Quebec issues draft budget 2018-2019
The Finance Minister of Quebec, Carlos Leitao, presented the province’s fiscal budget 2018-2019 on March 27, 2018. The main points of this budget is given below: This budget proposes gradual reduction of the Health Services Fund (HSF)
See MoreArgentina: CbC notification deadline extends for fiscal years ending
A Resolution entitled “General Resolution 4218 of 23 March 2018” was published in the Official Gazette. This gives an extension of the established term for the Country-by-Country (CbC) information system and also the due date to submit the
See MoreColombia: New income tax return form for 2017
The Colombian national tax authority (DIAN) published a new income tax return form 110 for tax year 2017. The tax payers are obliged to file their income tax return electronically using form 110. DIAN has also published a revised informative
See MoreBrazil changes R&D tax incentives
Brazil released the National Congress Act No. 8 of 14 March 2018 in the Official Journal. The Act extends by 60 Days of Provisional Measure No. 810 of 8 December 2017. This act changes the tax incentive for IT companies investing in research and
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