US: Issues Notice Requesting Comments on Transfer Pricing Penalties
The US Internal Revenue Service (IRS) and the Treasury Department have issued a notice requesting comments on transfer pricing penalties as per temporary and the final regulations. Under both the temporary and the final regulations the penalty may
See MoreArgentina-Double Tax Treaty with Switzerland enters into force
The new Double Taxation Treaty between Switzerland and Argentina will enter into force on 27 November 2015. The new treaty will be applicable from 1 January 2015. For taxes withheld at source the relief has become applicable from 2015. The new
See MoreCanada: Alberta fiscal budget for 2015-2016 issued
The Finance Minister of Alberta has presented the Province’s fiscal budget for 2015-2016 on 27th October 2015. The budget contains no changes to the personal income tax rates. However, some other new tax measures contained in the budget may
See MoreWorld Customs Organization Discusses the Future of Customs
The Permanent Technical Committee of the World Customs Organization (WCO) discussed the Future of Customs at its meeting of 14 to 16 October 2015. The meeting considered issues put forward by the WCO Virtual Working Group on the Future of Customs.
See MoreDTA between Chile and Italy signed
A Tax Treaty between Chile and Italy has been signed on 23rd October
See MoreAustria-Chile income tax treaty enters into force
The income tax treaty between Austria and Chile entered into force on 9 September 2015. The treaty generally applies from 1 January
See MoreUnited States: ADD/CVD Roundup for September 2015
Following table shows the Federal Register notices related to ADD/CVD cases for September 2015 in United States. Country Product Investigations Case Number Details Argentina Lemon Juice Countervailing Duty Order, Finding, or Suspended
See MoreUS and Czech Republic: Competent Authority Arrangement (CAA) signed
In accordance with the US and Czech Republic intergovernmental agreement (IGA) for implementing the Foreign Account Tax Compliance Act (FATCA), the competent authority arrangement (CAA) has been signed between the US and Czech Republic on 1st
See MorePGA Highlights: September 2015
In the United States the following events have taken place under the several PGA during the month of September 2015. Agencies Summary Link Federal Register Eligibility for exporting meat products to the US: The Food Safety and Inspection
See MoreColombia: National Tax Authority Issued Transfer Pricing Rules on Sales of Intangibles
The National Tax Authority of Colombia announced on sale transactions of intangibles subject to the transfer pricing regime. In article 260-1 of the Tax Code provides criteria for ascertaining whether two or more parties are related parties and the
See MoreUS: IRS Released Temporary Regulations to Clarify that the Arm’s-Length Standard of Section 482 Applies to all Controlled Transactions
IRS issued Treasury Decision 9738 on 14 September 2015 containing temporary regulations under Section 482 clarifying the application of the arm’s-length standard when multiple code sections. The temporary regulations apply to tax years ending on
See MoreCanada and Spain: Protocol to DTA will enter into force
The amending protocol of the Income and Capital Tax Treaty (DTA; 1976) between Canada and Spain will enter into force on 12th December 2015 and it was signed on 18th November 2014. The effective date for withholding taxes on amounts paid or credited
See MoreDTA between Chile and Japan will be negotiated
The first round of negotiations for a tax treaty between Chile and Japan will take place from 1st October
See MoreWTO: Trade Policy Review of Guyana
The World Trade Organization (WTO) conducted a trade policy review of Guyana on 15 and 17 September 2015. To prepare for the review a report was written by the WTO Secretariat. Guyana’s economic performance has improved in recent years with
See MoreBrazil: Government declares new tax measures
Brazil’s Executive branch has proposed different tax measures that would decrease the expected 30 billion Reais (R$) deficit for 2016 to avoid a budget deficit. Tax incentives Under the proposal, tax incentive for export companies will reduce
See MoreArgentina- extended employment promotional regime
Decree No. 1,801/15 was published in the Argentine Official Gazette on 8 September 2015. By means of the Decree the Argentine Government has extended the Employment Promotional Regime (that initially expired on 30 July 2015) for a further period of
See MoreUruguay-Proposed Budget Bill for 2015-19
Uruguay’s government has submitted to the Congress the Bill of the National Budget for the years 2015 up to 2019 on 31 August 2015. If enacted the bill would make significant changes to the tax laws. According to the proposal, income derived from
See MoreSlovak Republic and US: FATCA agreement approved by Slovak Republic
The FATCA Model 1A agreement (2015) between the Slovak Republic and the United States was approved on 28th August 2015 by the Slovakian government and has now been submitted for ratification to the National
See More