Chile: Tax authority clarifies time limits for MAP requests
On 19 April 2023, Circular No. 19 was released by the Chilean tax authority. This circular modifies Circular No. 13, which was published on 18 March 2022, which provides guidance on the Mutual Agreement Procedures (MAP) under Chile’s tax treaties.
See More
Brazil publishes law extending certain CFC benefits
On 13 April 2023, Law No. 14.547 transposing Provisional Measure 1148/2022 into law was published in the Brazilian Official Gazette, which extends certain benefits in regard to the controlled foreign company (CFC) rules under Law 12,973/14. Under
See More
Canada: Tax measures in federal budget 2023
On 28 March 2023, Ms. Chrystia Freeland, the Deputy Prime Minister and Minister of Finance released Budget 2023. Canada’s economic growth was the strongest in the G7 over the last year, and today, 830,000 more Canadians are employed than before
See More
Brazil: Lower House passes transfer pricing reform measure
On 30 March 2023, the Brazilian Lower House of Congress adopted Measure No. 1,152 to overhaul its transfer pricing system that was introduced on 29 December 2022. In addition to introducing the arm's length principle into the Brazilian transfer
See More
US and Germany sign CAA regarding CbC exchange arrangement
On 24 March 2023, US and Germany signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. The Competent Authorities desire to conclude this Arrangement on the exchange of CbC Reports based on domestic reporting and
See More
Costa Rica extends filing deadline for inactive entities
On 29 March 2023, Costa Rica issued Resolution No. MH-DGT-RES-007-2023 providing an extension of filing annual informative return for inactive entities. Usually, inactive entities are required to file their informative return by 30 April of each
See More
Chile launches public consultation on MAP
The Internal Revenue Service (SII) of Chile has launched a public consultation on a draft circular that aims to clarify the 3-year deadline for submitting a mutual agreement procedure (MAP) request. The SII is accepting feedback from the public
See More
Mexico deposits ratification instrument for BEPS MLI
On 15 March 2023, Mexico deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). The Convention will enter into force in relation to Mexico on 1 July 2023.
See More
US: Tax proposals under the budget for fiscal year 2024
On 9 March 2023, U.S. President Joe Biden released the Fiscal Year 2024 Budget introducing following tax proposal. Ensures Corporations Pay Their Fair Share: The Budget includes an increase to the rate that corporations pay in taxes on their
See More
Brazil publishes law reducing WHT rate on cross-border payments
On 28 February 2023, the government of Brazil has published Law no. 14,537, which reduces the withholding tax rates for cross-border payments related to travel to foreign individuals or entities residing or having their registered offices
See More
Brazil issues normative instruction establishing new transfer pricing regulations for 2023
On 24 February 2023, the Brazilian Federal Revenue Office published the Normative Instruction No. 2.132 which establishes the regulation of the taxpayer's choice to apply the new transfer pricing rules according to Provisional Measure (PM) No.
See More
Colombia amends the tax return and payment deadline in 2023
On 15 February 2023, the Colombian Ministry of Finance published Decree 0219 amending the deadlines for filing and payment of the tax return (declaration) in 2023 for specific taxpayers. Some of the key deadlines for companies depend on the last
See More
US: IRS extends the tax relief measures for taxpayers in disaster area
On 24 February 2023, the Internal Revenue Service announced that tax relief measures for disaster area taxpayers in California, Alabama and Georgia has been further extended to 16 October 2023. Previously, the deadline had been postponed to May 15
See More
US: IRS and Treasury issue final regulations on e-file for businesses
On 21 February 2023, the Department of the Treasury and the Internal Revenue Service issued final regulations T.D. 9972 amending the rules for filing returns and other documents electronically (e-file). These regulations will require certain filers
See More
US: IRS publishes interest rates on overpaid and underpaid tax for Q2 of 2023
On 13 February 2023, the Internal Revenue Service announced the interest rates for the calendar quarter beginning April 1, 2023. The rate will remain same as first quarter. Here is a complete list of the new rates: 7% for overpayments (payments
See More
Germany: Lower house of parliament adopts CbC exchange agreement with USA
On 9 February 2023, the German lower house of parliament (Bundestag) has approved a law to ratify the pending agreement with the USA on the exchange of CbC reports. The agreement was signed on 14 August 2020. The agreement will enter into force when
See More
Puerto Rico: Governor proposes tax relief for individuals and corporations
On 6 February 2023, Mr. Pedro Pierluisi, Governor of Puerto Rico unveiled a set of proposals aimed at enhancing and streamlining Puerto Rico's tax system. The proposals include reducing the tax burden for individuals and corporations by over $500
See More
US: Tax court approves agreement resolving APA cancellation case
On 3 February 2023, the US Tax Court issued a rule approving an agreement between Eaton Corporation and the IRS to adjust Eaton's tax bill for 2005 and 2006 to USD 8.8 million. The proposal stems from lengthy litigation in both the Tax Court and
See More