Australia and Chile: DTA will be applicable after 1 January 2014 in Chile
The Convention between the Republic of Chile and Australia for the Avoidance of Double Taxation was published in Chile’s Official Gazette on 23 July 2013. The treaty was signed on 10 March 2010 and entered into force on 8 February 2013. The
See MoreChile: Taxpayers must submit new affidavit following transfer pricing rules
Taxpayers who are engaging in transactions with entities domiciled abroad will have to agree with the new transfer pricing compliance requirements. Taxpayers will have to submit the Transfer Pricing (TP) annual information return form to the Chilean
See MoreCanada – Way of taxation in foreign affiliates
The draft legislation has released by Canada’s Department of Finance on July 12, 2013, including provisions concerning the taxation of foreign affiliates and non-resident corporations without share capital, the foreign currency election,
See MoreUruguay: New rules regarding foreign tax credit
The tax authorities of Uruguay issued Resolution No. 1,815/2013 regarding new rules on foreign tax credit on 26 June 2013. The resolution sets out the requirements for benefiting from foreign tax credits under the domestic law or tax treaties.
See MoreUruguay: National Assembly presents Budget Bill 2012
The government of Uruguay presented a Bill to the National Assembly on 30 June 2013 that reviews the 2012 Budget. Capital gains on bearer shares have become subject to individual income tax (IRPF) and non-resident income tax (IRNR) unless particular
See MoreIndia: Treaty between India and Uruguay enters into force
The Income and Capital Tax Treaty between India and Uruguay entered into force on 21 June 2013. The treaty generally applies from 1 January 2014 for Uruguay and from 1 April 2014 for India. This treaty was signed in September 8, 2011. Under the
See MoreMalta and US FATCA negotiations oncluded
Recently negotiations concerning an Intergovernmental Agreement (IGA) relating to US FATCA regulations (FATCA) have been concluded between Malta and the US. Financial institutions must comply with certain prescribed reporting obligations for the
See MoreChile: Circular notifying transfer pricing changes
The Chilean Internal Revenue Service (IRS) has released Circular No. 29 on June 14, 2013 that includes instructions regarding the new transfer pricing rules introduced by Law 20,630. The circular recognizes the OECD TP Guidelines as a valid source
See MoreArgentina: New investment regime for the oil and gas industry
The Executive power of Argentina issued Decree N° 929/2013 to encourage investments in the oil and gas regime through new system. The Decree was published in the Official Gazette on July 15, 2013. According to the Decree eligible entities of the
See MorePeru: Changes to transfer pricing documentation requirements
The Resolution 175-2013 of Peru sets out regulations concerning new transfer pricing documentation requirements which have become effective from 1 June 2013. According to the new rule taxpayers subject to the transfer pricing rules are required to
See MoreCanada: Extended CIT return deadline
Businesses in parts of Canada including Alberta have recently been affected by extreme weather conditions. This has caused damage to premises and delays in completing administrative tasks. In response to this problem the Canada Revenue Agency (CRA)
See MoreColombia and Mexico DTA will enter into force on 11 July 2013
The Income and Capital Tax Treaty between Colombia and Mexico will enter into force on 11 July 2013. The treaty will be applicable in Mexico from 1 January 2014 and in Colombia from 1 January 2014 for income tax matters and from 11 July 2013 for
See MoreDTA between Ecuador and Singapore signed
Singapore and Ecuador signed an Agreement for the Avoidance of Double Taxation (DTA) on 27 June 2013. The provisions of the treaty will have effect from 1 January of the calendar year next following that in which the agreement enters into
See MoreCanada: Extra GST/HST return for large businesses
Certain large businesses, in addition to filing their regular GST/HST returns will have to face an extra GST/HST (goods and services tax / harmonized sales tax) filing requirement on June 30, 2013. Employers offering registered pension plans to
See MoreArgentina: New process for determining “tax haven” jurisdictions
Argentina’s tax authority (AFIP) has issued a decree introducing new criteria for when to consider countries as “tax haven” jurisdictions for transfer pricing purposes. This Decree was published on May 30, 2013. The Decree states that the AFIP
See MoreBrazil: Increase in revenue limit to opt for presumed profit method
The government of Brazil has again increased the gross income limit for companies to opt for taxation under the presumed profit regime. Companies electing to use the presumed profit method are taxed on a statutory rate applied to their gross
See MoreCanada – Tax-related interest rates for 2014
It was announced by the Canada Revenue Agency (CRA) that tax-related interest rates for taxable credits and for tax overpayment and underpayments for the third quarter of 2013 (July 1- September 30) will remain unchanged for this year and the rates
See MoreUnited States: IRS publishes quarterly list of individuals who have expatriated
The US Internal Revenue Service (IRS) has published a quarterly notice with a list of US citizens and long-term US residents who have renounced their citizenship or residency for US federal tax purposes. The Notice is required under section 6039G
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