US: Treasury Department and IRS Released Temporary Regulations and Proposed Regulations to Clarify the Arm’s Length Standard
The Treasury Department and IRS released for publication in the Federal Register Temporary regulations (T.D. 9738) on 15 September 2015 to clarify the arm’s length standard and the best method rule under Code section 482 and the regulations
See MoreMexico: Tax reform proposal submitted to congress
The Mexican tax reform proposal presented to congress on September 8, 2015 which includes supplementary transfer pricing documentation requirements in line with the three-tiered approaches of Action 13 of the OECD like master file and local file
See MoreCanada: Conservative party pledges payroll tax cut
The Prime Minister of Canada has declared that a re-elected conservative government would cut more than 20% payroll taxes in 2017. He promised that his government would not increase payroll taxes in the Canada Pension Plan (CPP) and also accused the
See MorePeru: Proposal for CGT exemption for certain transfers of shares
The President presented to the Peruvian Congress on 24 August 2015 a bill proposing temporary tax exemptions from capital gains tax arising from the transfer of shares carried out through the Lima Stock Exchange. To obtain the exemption certain
See MoreCanada: Quebec Finance Minister considering sales tax increases
The Finance Minister in Quebec has stated that his Government is allowing for a 1% percent rise in the provincial sales tax. At present, the Quebec Sales Tax (QST) rate is 9.98%. The Government intentions to announce the changes in the next Budget.
See MoreChile and Uruguay: TIEAs approved by Uruguay
The Exchange of Information Agreement (TIEA; 2014) between Chile and Uruguay has been approved by the Senate of Uruguay on 1st September 2015 and it still needs to be enacted by the President and then ratified by
See MoreChile and United States: DTA approved by Chilean Senate
The Income and Capital Tax Treaty (2010) between Chile and United States has been approved on 1st September 2015 by the Chilean
See MoreChile and Austria: DTA approved by Chilean Senate
The Income and Capital Tax Treaty (2012) between Chile and Austria has been approved by the Chilean Senate on 1st September
See MoreCanada: Prime Minister promises to improve mining tax credit
The Prime Minister of Canada has made a promise that if re-elected, his Government would prolong the mineral exploration tax credit for 3 years to 2019. As part of his election campaign, the Prime Minister also declared that his government would
See MoreUnited States: ADD/CVD Roundup for August 2015
Following table shows the Federal Register notices related to ADD/CVD cases for August 2015 in United States. Country Product Investigations Case Number Details Australia Certain Uncoated Paper Preliminary Determination of Sales at Less Than
See MorePGA Highlights: August 2015
In the United States the following events have taken place under the several PGA during the month of August 2015. Agencies Summary Link Federal Register Eligibility to Lithuania for exporting meat and meat products to the US: The Food Safety
See MoreChile: Reporting process of indirect transfer of shares published
The Resolution No. 65 has been issued on 30th July 2015 and published on the tax administration's website. As described under article 10 and paragraph 3 of the Income Tax Law on about the indirect transfer of shares, this resolution controls
See MorePeru – Tax incentives for R&D sector
In Peru Decreto Supremo No. 188-2015-EF was published in the official gazette on 12 July 2015. The decree made certain tax incentives available for taxpayers that invest in research projects or that are involved in scientific, technological
See MorePeru – Draft law on tax incentives to promote investment in stock market
The parliament of Peru published Draft Law No. 4743/2015-PE on 26 August 2015. The Draft law proposes certain tax incentives designed for increasing investment in the stock market. The proposed tax incentives are as follows: -Providing exemption
See MoreCanadian non-resident permitted to carry-forward of non-capital losses
The Canadian Tax Court issued a decision regarding a case entitled Hatt v. The Queen (2015 TCC 207) on 19th August 2015. The issue was whether the taxpayer was entitled to deduct a non-capital loss from employment in Canada in the 2010 tax
See MoreCanada: CRA issues 2014-15 APA program report
The Canada Revenue Agency (CRA) has published a report on 17th August 2015 regarding Advance Pricing Arrangement (APA) program for the period from 1st April 2014 to 31st March 2015. This gives an overview of the systems of APA program containing
See MoreBulgaria-US: FATCA agreement entered into force
In accordance with a declaration made in the Bulgarian State Gazette on 26th June 2015, the FATCA Model 1B Agreement (2014) between Bulgaria and United States has entered into force on 30th June 2015. An intergovernmental agreement (IGA) for the
See MoreCanada: CRA releases annual MAP report
The Canada Revenue Agency (CRA) has published its 12th annual report regarding its Mutual Agreement Procedure (MAP) programme. The report gives the objective, history, and present events of the MAP programme for the period from 1st April 2014 to
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