US: IRS publishes join statement with France on exchange of CbC reports for FY 2022-2023
On 7 December 2022, the Internal Revenue Service (IRS) published a joint statement with the competent authority of the United States of America and the competent authority of the French republic on the implementation of the spontaneous exchange of
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US: IRS publishes interest rates on overpaid and underpaid tax for Q1 of 2023
On 29 November, the Internal Revenue Service announced that interest rates will increase for the calendar quarter beginning January 1, 2023. For individuals, the rate for overpayments and underpayments will be 7% per year, compounded daily, up
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Ecuador submits a draft bill in the parliament on tax incentives for audiovisual and energy sectors
On 24 November 2022, the government of Ecuador submitted a draft bill in the National Assembly that provides incentives for audiovisual and energy sectors. The incentives include: A remittance tax exemption on expenditures occurs for carrying
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US: IRS issues guidance related foreign tax credit
On 22 November 2022, the U.S. Internal Revenue Service issued a guidance relating to the foreign tax credit, including guidance with respect to the reattribution asset rule for purposes of allocating and apportioning foreign taxes, the cost recovery
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Germany publishes a draft bill updating list of participating jurisdictions under MCAA-CbC
On 23 November 2023, the German Ministry of Finance published a draft bill providing an updated list of jurisdictions participating under the Multilateral Competent Authority Agreement (MCAA) on the exchange of CbC reports. Accordingly, Germany will
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Mexico ratifies BEPS multilateral convention
On 22 November 2022, the Mexican President approved a Decree for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Mexico signed the MLI on 7 June 2017. Mexico
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Argentina: Commission on foreign affairs endorses a bill to ratify MLI
On 8 November 2022, the Argentine Commission on Foreign Affairs accepted a bill to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). On 7 June 2017, Argentina signed the MLI containing a
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Costa Rica extends the deadline for filing informative returns for dormant companies
On 9 November 2022, Costa Rica published the Resolution No.DGT-R-033-2022 regarding further extension of deadline for filing informative returns for dormant companies. This is the third extension of the filing deadline. Previously, it was extended
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Germany: Federal Cabinet approves CbC reports exchange agreement with US
On 4 November 2022, the German Upper House of Parliament (Bundesrat) approves bill No. 567/22 for consideration to ratify the competent authority agreement (CAA) on the exchange of country-by-country (CbC) reports with the US. The competent
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Cyprus: Clarification Bilateral Agreement for exchange of CbC between Cyprus and the USA
On 13 October 2022, the Cyprus tax authority informed all legal entries and their representatives that the bilateral Competent Authority Arrangement (CAA) for the exchange of Country-by-Country (CbC Reports) between Cyprus and the United States of
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Mexico: Senate approves BEPS MLI
On 12 October 2022, the Mexican Senate approved the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Mexico signed the MLI on 7 June 2017. Mexico must now deposit its ratification
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Colombia: Congress approved Tax Reform Bill in the first debate
On 6 October 2022, the Colombian Congress approved Tax Reform Bill in the first debate. The Bill was presented to Congress on 8 August 2022. After the final approval of the Bill, the changes will become effective as of 1 January 2023. The main tax
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Peru: SUNAT updates the list of high-risk tax planning schemes regarding GAAR
On 11 October 2022, the Peruvian Tax Administration (SUNAT) published second version of the list of high-risk tax planning schemes regarding the General Anti-Avoidance Rule (GAAR). The updated list contains the following thirteen tax planning
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Puerto Rico extends tax returns and payment deadline due to Hurricane Fiona
On 27 September 2022, the Puerto Rico Treasury Department (PRTD) issued Administrative Determination No. 22-08 extending the due date for income tax returns and tax payments due to Hurricane Fiona. The PRTD extends the tax returns deadline until
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Turkey approves effective date on CAA regarding CbC exchange arrangement with US
On 13 September 2022, the Turkish Revenue Administration issued Presidential Decision No. 6033 in the Official Gazette, through which Turkey has approved the effective date of the Competent Authority Agreement (CAA) to exchange country-by-country
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Dominican Republic: DGII Publishes general standard rule on MAP
On 30 August 2022, the Dominican Tax Authorities (DGII) issued a new general standard rule on Mutual Agreement Procedures (MAP) for Dispute Resolution under the country's tax treaties. The general rules introduced details for submitting MAP
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On 8 September 2022, a draft bill was submitted to the Peruvian Congress for the ratification of the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI). Peru signed the convention on 27
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Argentina: MoE publishes new late tax payment and refund interest rates
On 23 August 2022, the Argentine Ministry of Economy published Resolution 559/2022, which provides new rates for late tax payments and reimbursement interest. The latest repeals Resolution 598/2019, which established rules for setting interest rates
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