Puerto Rico amends income tax law for deduction of intercompany charges
Recently, Puerto Rico has amended Section 1033.17(a)(17) of the Puerto Rican Internal Revenue Code of 2011 regarding intercompany expense allocation. Previously there was a disallowance of 51% of intercompany charges. According to the amendment,
See MorePanama introduces CbC registration process via AEOI portal
The FATCA & AEOI Portal of Panama's Directorate General of Revenue (DGI) is now accepting registration for Country-by-Country (CbC) report presentation and notification purposes, as well as for FATCA and CRS purposes. The CbC reporting
See MoreDominican Republic: DGII issues transfer pricing documentation thresholds for 2020
On January 15, 2020, Directorate General of Internal Revenue (DGII) published the Transfer pricing (TP) reporting threshold for 2020. The related party transaction threshold for transfer pricing reporting purposes in 2020 is DOP11,552,402. The
See MoreCanada: Reminder for the CbC reporting form submission process
On 9 January 2020, Government announced that as from 1st June 2020, Canadian ultimate parent entities that are corporations must file the RC4649 electronically using EFILE or Web Access Code (WAC). It will be available through CRA-T2-certified
See MoreArgentina: Government publishes General Resolution on dividend WHT rate
On 14 January 2020, the Government issued a General Resolution 4662/2020, which establishes procedures and deadlines for withholding tax payments on dividends paid by a permanent establishment to its parent company. With effect as from 14 January
See MoreCosta Rica: Ministry of finance publishes draft resolution on tax benefit for SMEs
The Costa Rican Ministry of Finance recently published a draft resolution on tax benefits for SMEs that was introduced by Law No. 9635 of 3 December 2018. The benefits apply to qualified SMEs whose gross income does not exceed CRC 106 million
See MoreColombia publishes a decree on tax return and TP documentation deadline
On 23 December 2019, Colombian tax authority (DIAN) has published Decree No. 2345 specifying the deadlines for filing and payment of the tax return (declaration) for 2020 and the deadline for transfer pricing (TP) documentation, including
See MoreMexico publishes Annexes to Miscellaneous Tax Resolution 2020
On 9 January 2020, Mexico has published Annexes 3, 5, 7, 8 and 11 of the Miscellaneous Tax Resolution for fiscal year 2020 in the Official Gazette. Annexes refer to the following issues: Annex 3 of the Miscellaneous Tax Resolution 2020 The
See MoreChile: Chamber of Deputies approves ratification of BEPS MLI
On 9 January 2020, the Chamber of Deputies approved a Bill for the ratification of the multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). The Chile now has to deposit its instrument of ratification in order to
See MorePeru issues Supreme Decree to amend rules on capital gains tax exemption
On 30 December 2019, Peru has issued Supreme Decree 410-2019-EF that modifies the capital gains tax exemption rules. The Decree amends Supreme Decree 382-2015-EF that approved the Law No. 30341, which extends the exemption from tax on income from
See MoreColombia enacts amended tax reform law
On 27 December 2019, Colombia has enacted tax reform law (Law 2010), which replaces the previous tax reform (Law 1943). The previous Law was held to be unconstitutional by the Constitutional Court on 16 October 2019 but was allowed to be in force
See MoreEcuador: Government publishes tax reform for 2020
On 31 December 2019, the Government published tax reform 2020 through Law of Simplicity and Tax Progressivity (Law No. SAN-2019-1270) in the Official Gazette. The Law effects from 1 January 2020. Some of the key provisions are given
See MoreDTA between Ecuador and Japan enters into force
On 28 December 2019, the Double Taxation Agreement (DTA) between Ecuador and Japan was entered into force and applies from 1 January 2020. The DTA contains Dividends rate 5%, Interest rate 10%, and Royalties rate
See MoreEcuador: President made objections on second tax reform bill
On 14 December 2019, the President, Moreno, made objections on the second tax reform bill approved by the National Assembly. Accordingly, he proposed to limit the application of the thin-capitalization rules to inter-company loans. Accordingly,
See MorePanama extends CbC reporting deadline and notification
On 27 December 2019, Directorate General of Revenue of Panama has issued Resolution No. 201-9116 and 201-9117, with effect from the date of publication. Resolution No. 201-9116 extends the filing of Country by Country (CbC) reporting until 31
See MoreCosta Rica: Ministry of Finance publishes draft resolution on APA guidelines
In December 2019, the Costa Rican Ministry of Finance released a draft resolution regarding the procedures for processing advance pricing agreements (APAs). The draft guidelines state that APA applications would need to be addressed to the
See MoreArgentina: Tax Authority publishes Law 27541 for implementing tax reform 2020
On 23rd December 2019, Argentina published Law 27541 regarding Social Solidarity and Productive Reactivation in the Official Gazette, which contains measures on corporate income tax, personal income tax, dividend withholding tax etc. The Law was
See MoreTax treaty between Colombia and the UK enters into force
On 16th December 2019, the Double Taxation Agreement (DTA) between Colombia and the United Kingdom (UK) was entered into force and applies from 1 January 2020. The DTA contains Dividends rate 0% if the beneficial owners is a pension fund or scheme,
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