US: Treasury department issues regulations removing documentation requirements
On 31 October 2019, the US treasury department issued final regulations (TD 9880), repealing section 385, which sets out minimum documentation requirements that must normally be met in order for certain related-party interests in a corporation to
See MorePeru extends capital gains tax exemption until 2022
On 24 October 2019, Peru issued Urgent Decree 005-2019 in the official gazette modifying Legislative Decree No. 30341. The Decree extends the exemption from tax on income from the sale of certain securities. The following values will be benefited
See MoreCanada: Finance Minister announces Alberta’s 2019 Budget
On 24 October 2019, the Finance Minister of Alberta, presented the 2019 province budget. The budget does not contain any new changes to the corporate or individual income tax rates. It excludes several tax credits, including the scientific research
See MoreUS: Tax Court issues an opinion in the case of Eaton Corp. v. Commissioner regarding APA
On 28 October 2019, the U.S. Tax Court published an order in the case of Eaton Corp. v. Commissioner related to advance pricing agreements (APAs). In that case, Eaton Corporation (P-Petitioner) and Commissioner of Internal Revenue
See MoreColombia: Government submits tax reform bill to Congress after court ruling
On 22 October 2019, the Colombian Government submitted a new tax reform bill to Congress that will replace tax reform bill 2019 (Law No. 1943 of 2018). The tax reform bill 2019, which came into force on 1 January 2019, is invalid due to procedural
See MoreMexico: Congress approves legislation considering tax fraud as organized crime
On 15 October 2019, Mexico’s Congress has passed legislation considering tax fraud as organized crime. Purchase or sale of false tax invoice, unlawfully obtains a tax subsidy, fails to include accrued income in a tax return or fails to remit VAT
See MoreColombia: Constitutional Court rules ‘Tax Reform Law 2019’ as unconstitutional
On 16 October 2019, the Colombian Constitutional Court ruled that the tax reform law 2019 was unconstitutional. The tax reform law 2019 (law No. 1943), which came into force on 1 January 2019, is invalid due to procedural flaws in the approval
See MoreChile: Tax authority describes foreign tax credits in case of dividends
The tax authority published a Letter No. 2625 of 16 October 2019 regarding credit for taxes paid abroad in case of dividends. It means where payment of dividends through a foreign intermediary, a foreign tax credit on the dividends is available
See MorePeru: SUNAT issues report on deductibility of interest paid to non-residents
On 9 October 2019, the Peruvian Tax Administration (SUNAT) has published Report No. 130-2019-SUNAT/7T0000 (guiedeline) on its website regarding deductibility of interest paid to non-residents. The deduction of interest on debts provided is
See MoreChile: President presents 2020 draft Budget
The President, Sebastian Pinera, announced draft budget for the year 2020. He said that they have passed a very crucial economic time due to the low copper prices and the trade war between China and the United States. The draft budget covers
See MoreBrazil: Federal Revenue approves Private Ruling 276/2019
On 2 October 2019, the Brazilian tax authorities released a private ruling PLR 276/2019 on tax treatment of cross-border cost sharing arrangements. The ruling provides a consultation solution that was requested by an entity whose direct parent
See MorePeru: SUNAT publishes resolution on submission of CbC reports
On 29 September 2019, the Peruvian Tax Administration (SUNAT) has published Resolution No. 188-2019/SUNAT in the Official Gazette, through which the comprehensive system for the reception and automatic exchange of information (IR AEOI system) was
See MoreArgentina: AFIP announces draft transfer pricing guidance for public comments
On 2 October 2019, tax authority of Argentina (AFIP) announced a public consultation and posted on the AFIP website a draft resolution concerning transfer pricing compliance procedures. It would replace the existing transfer pricing rules in
See MorePeru: SUNAT issues resolution on beneficial ownership of entities
On 25 September 2019, the Peruvian Tax Administration (SUNAT) has issued Resolution No. 185-2019/SUNAT establishing the procedure, deadlines and conditions for submitting the ultimate beneficiary informative return of entities. Effective from 1
See MoreCosta Rica publishes a resolution on the list of non-cooperative jurisdictions for tax purposes
On 25 September 2019, the Costa Rican Ministry of Finance published a resolution No. DGT-R-55-2019 on the list of non-cooperative jurisdictions for tax purposes. The list includes Bosnia and Herzegovina, Cuba, Eritrea, French Polynesia, Guadeloupe,
See MorePeru: SUNAT publishes report on GAAR
On 17 September 2019, the Peruvian Tax Administration (SUNAT) published Report No. 116-2019-SUNAT / 7T000 of 27 August 2019 on its website, through which SUNAT clarifies the application of General Anti-Avoidance Rule (GAAR). On 19 July 2012,
See MoreUruguay ratifies BEPS multilateral instrument
On 18 September 2019, Mr. Tabaré Vázquez, the president of Uruguay signed the law for the ratification of the multilateral convention to implement Double Taxation Agreement (DTA) related measures to prevent Base Erosion and Profit Shifting
See MoreUS: IRS publishes final and proposed regulations on new 100% depreciation
On 13 September 2019, the Treasury Department and the Internal Revenue Service published final regulations and additional proposed regulations under section 168(k) of the Internal Revenue Code on the new 100% additional first year depreciation
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