Canada – New withholding rules and information collecting rules under the FATCA
Under the U.S. Foreign Account Tax Compliance Act (FATCA), Canadian banks and certain other non-U.S. entities must allow with new rules of withholding and information collecting requirements that take effect on June 30, 2014. In respect of FATCA
See MoreCanada: New exempt life insurance policy rules proposals
A number of amendments that would implement changes to the elimination test and other life insurance policy holder taxation rules have been published by the Canada’s Finance Department. Again, the proposals would amend the rules applying to the
See MoreMexican Tax Authority increases focus on auditing supply chain structures
Recent developments within the Mexican Tax Administration Services (SAT) demonstrate an increased focus on auditing supply chain restructurings. This is in line with international trends in transfer pricing, for example the report on business
See MoreSwitzerland agrees plans for settling US Tax conflict
The Federal Council of Switzerland has agreed to plans for reconciling the Confederation’s tax conflict with the US. The Council of the Federal Finance Department has established a mutual statement designed to draw a line under past dispute over
See MoreBrazil: Guidance Issued on the Pricing of Interest Bearing Transactions
The Brazilian Ministry of Finance has issued an ordinance 427/2013, On 2 August 2013, which finally define and clarifies the interest rate spread and that was mentioned but not specified in Law 12.766/2012. Under Ordinance 427/2013 where the
See MoreCanada – Amends to foreign affiliate dumping rules proposed by the Government
The draft legislation has introduced on August 16, 2013, to make revisions to the foreign affiliate dumping (FAD) rules that were first declared as part of the 2012 federal budget and enacted on December 14, 2012 according to Bill C-45 and it would
See MoreColombia: Agreement with World Bank on Tax Matters
The World Bank signed an agreement with Colombia on August 19, 2013. This is to improve its tax collection. The agreement will be in force between August 2013 and August 2015. In order to strengthening the tax system, the World Bank will supply
See MoreUruguay enacts limits on tax incentives
Uruguay has issued Decree No. 226/013 which introduces a new ceiling on the tax credit for donations to art and cultural projects. The new ceiling applies from 14 August 2013. Under the new provisions, the maximum amount of tax credit on donations
See MoreVenezuela: New income tax relief
The Official Gazette of Venezuela has published a decree named “Supreme Decree 285”. This decree has brought new income tax discharges which will be effective from January 1, 2013 to December 31, 2015. The forestry and agricultural sectors are
See MoreCanada – Amendments in foreign income verification statement
It has been officially confirmed by the Canada Revenue Agency (CRA) that the revised Form T1135 applies to tax years ending after June 30, 2013 whereas the old form T1135 (Foreign Income Verification Statement) will still be approved for tax years
See MoreBrazil terminates Provisional Measure 612/2013
The measure to extend the presumed profit regime and make other relevant changes to the Brazilian tax law has been revoked. Provisional Measure 612/2013 was not converted into law by the National Congress within the extended 120 calendar-day period
See MoreArgentina – Mandatory online tax return system
From 1 August 2013 is has become compulsory for every Argentine taxpayers to use the online tax return system (SIFERE) to report gross revenue to local jurisdictions. Resolución General 7 was published in the official gazette on July 23, 2013 which
See MoreSingapore and Barbados sign a new DTA
Singapore and Barbados signed their first income tax treaty On 15 July 2013.The provisions of the treaty generally follow the provisions of the OECD Model Tax Convention but a permanent establishment is created if services are provided in the other
See MoreRussia planning to implement rules to follow FATCA
One of the main issues facing Russian financial institutions is the fact that recent legal obstacles do not allow them to follow the US Foreign Account Tax Compliance Act (FATCA) in Russia by entering into direct contracts with the Internal Revenue
See MoreProtocol to DTA between Austria and Canada signed
A second protocol to the Austria –Canada Income Tax Treaty which was signed on 1 March 2012 will enter into force on 1 October 2013. The protocol contains provisions for the exchange of tax information and will have effect in accordance with the
See MoreUnited States and Swiss agree on FATCA signification
The United States and Swiss governments have signed a memorandum of understanding on interpretations of their agreement on implementing the Foreign Account Tax Compliance Act, or FATCA on 7 June 2013 in Washington. The memorandum summarizes the
See MoreEU: FTA with Peru and Colombia
A free trade agreement (FTA) between the EU, Peru and Colombia signed on 26 June 2013.The agreement will enter into force after ratification procedures are completed. The agreement introduces technical and procedural obstacles to trade. The
See MoreEU: FTA between Colombia and EU entered into force
The European Commission announced on 26 July 2013 that the Free Trade Agreement (FTA) between the European Union and Colombia will enter into force on 1 August 2013. This agreement was signed on 26 June
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