Canada releases revised draft DST Act for public comments
On 4 August 2023, the Department of Finance Canada published a revised draft of the Digital Services Tax (DST) Act for public consultation. These legislative proposals would implement the Digital Services Tax Act. The Act would impose a tax
See More
Paraguay upgrades transfer pricing documentation process
On 20 July 2023, the tax authority of Paraguay (SET) issued General Resolution No. 134 of 18 July 2023, that introduces an exceptional mechanism for the submission of the technical transfer pricing study (Estudio Técnico de Precios de Transferencia
See More
Canada releases draft Global Minimum Tax Act for public comments
On 4 August 2023, Canada issued draft legislation aimed at implementing the "Pillar Two" global minimum tax framework established by the Organisation for Economic Co-operation and Development (OECD) and the G-20 Inclusive Framework on Base Erosion
See More
WTO: World Trade Statistical Review 2023
On 31 July 2023 the WTO published the World Trade Statistical Review 2023. The report looks at the patterns of world trade in 2022 and gives some insights into the outlook for 2023. The regularly updated statistics on world trade provide a
See More
IMF Report looks at the Economy of Brazil
On 31 July 2023 the IMF issued a report following talks with Brazil under Article IV of the IMF’s articles of agreement. Although economic growth in the first part of 2023 has been buoyed by strong agricultural output, manufacturing and
See More
US: final regulations on carryback of consolidated net operating losses
On 12 July 2023, the U.S. Treasury Department and IRS released final regulations in the federal register that affect corporations filing consolidated returns. These regulations permit consolidated groups that acquire new members that were members
See More
Canada plans to enact DST in 2024
On 12 July 2023, Canadian Deputy Prime Minister and Minister of Finance said “two years ago, we agreed to pause the implementation of our own Digital Services Tax (DST), in order to give time and space for negotiations on Pillar One. But we were
See More
Panama introduces updated income tax return forms
On 27 June 2023, Panama officially published Resolution No. 201-4370/2023 in the Official Gazette, that introduces updated forms for filing income tax returns. These new forms are applicable to various entities, including individual taxpayers, legal
See More
Peru shifts from LIBOR to SOFR for lower withholding tax on nonresident interest
On 29 June 2023, Peru published Supreme Decree 137-2023 in the Official Gazette for the adoption of the Secured Overnight Financing Rate (SOFR) to replace the London Interbank Offered Rate (LIBOR). The Decree came into force on 30 June 2023. This
See More
Colombia: Ministry of Finance issues draft decree on significant economic presence rule
On 30 June 2023, the Colombian Ministry of Finance issued a draft decree on the significant economic presence (SEP) rule as a part of Law 2277 of 2022 (tax reform law). The SEP rule was introduced in the context of digital services taxation. The SEP
See More
US: IRS issues practice unit on categorization of income and taxes into proper basket for FTC
On 15 May 2023, the U.S. IRS published a practice unit regarding Foreign Tax Credit - Categorization of Income and Taxes Into Proper Basket. This Practice Unit is revised to address changes from the implementation of the Tax Cuts and Jobs Act (TCJA)
See More
US: IRS publishes practice units on interest expense limitations
On 16 May 2023, the IRS Large Business and International (LB&I) division issued two practice units in relation to interest expense limitations for related party loans. Interest Expense Limitation on Related Foreign Party Loans Under IRC
See More
Mexico: BEPS MLI enters into force
On 3 July 2023, OECD published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, MLI entered into force for
See More
OECD: Tax Transparency In Latin America 2023
On 27 June 2023 the OECD published Tax Transparency in Latin America 2023, during the latest meeting of the Punta del Este initiative. The Punta del Este Declaration aimed to tackle tax evasion and avoidance and other financial crimes by promoting
See More
Panama extends deadline for transfer pricing return
On 26 June 2023, the Panamanian tax authority issued Resolution No. 201-5949, that announced an extension of the deadline for calendar year taxpayers to file transfer pricing return (Form 930) for fiscal year (FY) 2022. The original deadline of 30
See More
US: IRS issues guidance for the advanced manufacturing investment credit
On 14 June 2023, the Internal Revenue Service issued proposed regulations that provide guidance regarding the implementation of the elective payment provisions of the Advanced Manufacturing Investment Credit, established by the Creating Helpful
See More
Argentina: AFIP introduces new payment facility for outstanding tax on SMEs
On 17 May 2023, Argentine tax authority (AFIP) has published General Resolution No. 5361/2023 which introduce a new payment facility for outstanding tax, social security, and customs obligations due until 30 April 2023, containing related interest
See More
Brazil: President signs OECD-aligned transfer pricing rules
On 14 June 2023, the president Luiz Inácio Lula da Silva signed the Law No. 14,596 adopting Provisional Measure No. 1,152, which enacts significant changes to the Brazilian transfer pricing system that is aligned with the guidelines provided by the
See More