Canada: Reforming Temporary Foreign Worker program
Currently, Canadians have raised concerns about the Temporary Foreign Worker Program. A review of the Temporary Foreign Worker Program has been incorporated in the Economic Action Plan 2013 and legislation has been enacted to change the rules. It
See MoreBrazil: Expands Threshold for Companies for presumed Profit Method
The profit method is one of four calculation regimes that may be applied by some companies for the computation of profits for Brazil’s corporate income tax. This is a simplified regime that enables a company to pay tax based on a percentage of its
See MoreBrazil: Tax subtraction from donations and sponsorships
Decree No. 7,988/2013 was published in the Official Gazette of 18 April 2013 and in force as of that date. Individuals and legal entities under the actual profit regime can deduct sponsorships and donations made to the National Program for
See MoreColombia: Proposed Regulations for Bank Debit Tax
The Colombian Government is currently preparing a Decree, which will regulate the provisions of bank debit tax. This bank debit tax was introduced by Law 1607 of 2012. This proposed Decree will provide for exemptions and the refund of the bank debit
See MoreHungary: Proposed Changes to Transfer Pricing Rules
The Ministry of National Economy (’the Ministry’) of Hungary has proposed changes to Hungarian transfer pricing documentation requirements. They have introduced provisions relating to low value added services and specified criteria for selection
See MoreUS: Public comments requested on branch profits tax for foreign corporations
The US Treasury Department and the Internal Revenue Service (IRS) are requesting comments concerning regulations TD 8223 (Branch Tax), TD 8432 (Branch Profits Tax) and TD 8657 (Regulations on Effectively Connected Income and the Branch Profits
See MoreMexico: Mining royalty plan
A proposal to levy a new royalty tax on mining profits in Mexico, the world’s largest producer of silver, passed a congressional committee on 16 April 2013. The proposal would also increase penalties for mining concessions that have not been
See MoreArgentina –Modifications to the transfer pricing regulations through General Resolution N° 3,476
The Argentine Federal Tax Authorities issued General Resolution N° 3,476 on 10 April 2013. The Resolution has revised the transfer pricing compliance rules and introduced modifications to the current Transfer Pricing regulations. General Resolution
See MoreUS: Report on advance pricing agreements
The US report on advance pricing agreements issued on 25 March 2013 covers the activities of the program in 2012. At the beginning of 2012 the APA program was merged with the office of the competent authority (USCA) that is responsible for the
See MoreColombia: Introduces Corporate Tax Reforms
The Colombian Government has introduced measures relating to corporate tax changes. For the purposes of corporate tax, it redefined the concept of permanent establishment. Corporate income tax rate for companies and for non-resident companies
See MoreCanada – 2013 budget announcements
The Canadian budget proposals for 2013 were announced on March 21, 2013. The proposals include measures to combat tax evasion and to provide some help for companies in the manufacturing and mining sectors. There is no change to the corporate tax
See MoreUS: IRS invites public comments on Bilateral Safe Harbors for Certain Transfer Pricing Issues
The Internal Revenue Service (IRS) announced on March 15, 2013, that it is consulting interested parties on the development of a model memorandum of understanding (MOU) between Competent Authorities relating to transfer pricing safe harbors for
See MoreUS: IRS Announces Interest Rates on tax overpayments and underpayments for 2013 second quarter.
The US Internal Revenue Service has issued Revenue Ruling 2013-6 with the announcement of the interest rates on tax overpayments and tax underpayments for the calendar quarter beginning 1 April 2013. The rate will remain the same as in the previous
See MoreChile: Issuance of Resolution No. 14 of 2013
Resolution No. 14 of 2013 has been issued by the Chilean Internal Revenue Service (Chilean IRS) that contains the new Transfer Pricing Annual Informative Return for calendar year 2012 and the proper completing instructions. The deadline for filing
See MoreUnited States: IRS publishes quarterly list of individuals who have expatriated.
The US Internal Revenue Service 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 dated 29 January 2013, and is based
See MoreTreaty between Finland and Uruguay enters into force
The Income and Capital Tax Treaty between Finland and Uruguay entered into force on 6 February 2013. The treaty generally applies from 1 January 2014. The treaty is based generally on the model tax conventions of the OECD and UN. The definition of a
See MoreChile: New Transfer Pricing Compliance Requirement
A new transfer pricing compliance requirement has been introduced in Chile by Resolution No. 14 of 2013. According to the new rule Chilean taxpayers are required to file a Transfer Pricing Annual Informative Return (‘TP Return’) for calendar
See MoreLatvia –Mexico: Treaty enter into force
The treaty between Latvia and Mexico for the avoidance of double taxation which was signed on 20 April 2012 is to enter into force on 2 March 2013. The maximum withholding tax on dividends is 10%, reduced to 5% where the recipient company is the
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