Colombia clarifies Significant Economic Presence rules under corporate income tax regulations
The Colombian tax authority (DIAN) has released new guidance on how companies should interpret the concept of Significant Economic Presence (SEP) under the country’s corporate income tax rules. In Ruling 713, issued on 28 August 2024, DIAN
See More
US: IRS rules section 246(b) tax limit applies to GILTI, FDII income
The US Internal Revenue Service (IRS) Office of Chief Counsel (OCC) has released a memorandum (AM 2024-002) that examines how the taxable income limitation under the Internal Revenue Code (IRC) section 246(b) applies to both IRC section 951A global
See More
US: IRS to handle 400,000 employee retention credit claims
The US Internal Revenue Service (IRS) has issued the ERC claims update in a news release (IR-2024-263) on October 10, 2024, stating it is processing about 400,000 claims, representing approximately USD10 billion in eligible claims. Work on the
See More
US: Senator Wyden presses Pfizer to comply with pharma tax investigation
US Senate Finance Committee Chair Ron Wyden (D-OR), in a release, on 3 October 2024 announced that Pfizer is the sole company unwilling to cooperate with the Finance Committee's investigation into how major pharmaceutical firms utilise offshore tax
See More
US: IRS releases 2022 tax gap projections of USD 696 billion
The Internal Revenue Service in a news release (IR-2024-262) on 10 October 2024 announced the tax gap projections for tax year 2022, a detailed analysis showing the nation’s projected gross tax gap of USD 696 billion. This reflects the difference
See More
Mexico publishes guidance for tax incentives for key sectors in Yucatan’s industrial zones
The Mexican government has published guidelines for granting tax incentives to taxpayers engaged in productive economic activities within the Progreso I and Mérida I industrial welfare zones (industrial parks) in Yucatán state on 26 September
See More
Bolivia revises payment document rules for transactions over BOB 50,000
Bolivia's National Tax Service released Normative Resolution No. 102400000021 of 20 September 2024, which updated rules for documentation on transactions over BOB 50,000, effective for all individuals and entities. The Normative Resolution No.
See More
Canada consults taxation of vacant lands
Canada’s government has initiated public consultations concerning the potential taxation of vacant residentially zoned land. Announced in the Budget 2024, this initiative aims to motivate private landowners to develop unused properties. The
See More
Dominican Republic consults repeal of tax exemptions on financial transactions
The Dominican Republic’s Directorate General of Internal Revenue has introduced an online consultation forum regarding the proposed rule to repeal the previous administrative exemption granted to specific sectors about the 0.15% excise tax on
See More
US: IRS grants six-month filing extension for Exempt Organisation Business Income Tax Return
The US Internal Revenue Service (IRS) has granted certain applicable entities that are making an elective payment election a six-month automatic extension of time to file an original or superseding Form 990-T, Exempt Organisation Business Income Tax
See More
Peru approves retroactive application of APAs
The Peruvian Executive Branch has announced the approval of Legislative Decree No. 1662, dated 24 September 2024, which modifies the Advance Pricing Agreement (APA) provision in the income tax law to permit the retroactive application (roll-back) of
See More
Paraguay, Spain income tax treaty enters into force
The income tax treaty between Paraguay and Spain took effect on 14 October 2024. This agreement aims to enhance economic relations, encourage investments, and enhance bilateral cooperation in tax matters between the two countries. It seeks to
See More
US: IRS finalises rules for repatriating intangible property under Section 367(d)
The US Internal Revenue Service (IRS) and Treasury published the final regulations - Section 367(d) Rules for Certain Repatriations of Intangible Property in the Federal Register on 10 October 2024, which contains final additions and amendments to
See More
Dominican Republic unveils fiscal reform plans
The Dominican Republic introduced a draft Law on Fiscal Modernization aimed at modernising its tax system and increasing revenue on 8 October 2024. The reform is reviewing tax incentives for sectors like tourism and cinema, and it will introduce
See More
Brazil consults Qualified Domestic Minimum Top-Up Tax
Brazil’s Federal Revenue Service has initiated a public consultation regarding the additional social contribution to net profits (Contribuição Social Para o Lucro Líquido, CSLL). The consultation will be open from 4 October to 10 November,
See More
Chile: Parliament passes tax compliance bill
Chile’s Chamber of Deputies have passed the Tax Compliance Bill (Proyecto de Ley de Cumplimiento de las Obligaciones Tributarias). Earlier, Chile’s Senate approved the Tax Compliance Bill on 24 September 2024 which included key changes to
See More
Argentina gets first financial data exchange from the US
Argentina’s federal tax authority (AFIP) announced that it received its first exchange of financial account information from the US on 2 October 2024. Similarly, Argentina has issued a statement stating that it sent financial information
See More
US: Treasury releases list of boycott countries
The US Treasury published a notice in the Federal Register regarding the current list of countries that may necessitate participation in or cooperation with an international boycott on 1 October 2024. The countries identified include Iraq,
See More