PGA 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 MoreUS: 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 More