US: IRS and Treasury extend consultation deadline for proposed CAMT regulations
The US Treasury Department and Internal Revenue Service (IRS) have announced an extension for submitting comments on the proposed regulations (REG-112129-23) concerning corporate alternative minimum tax (CAMT) on 4 December 2024. Initially published
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Dominican Republic clarifies taxation of foreign dividends
The Directorate General of Internal Revenue (DGII) of the Dominican Republic issued a consultation letter offering clarification regarding the taxation of foreign dividends received by residents on 15 August 2024. The letter clarifies that:
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Canada announces personal income tax rates for 2025
The Canada Revenue Agency (CRA) released the Indexation Adjustment For Personal Income Tax And Benefit Amounts from 2022 to 2025 on 15 November 2024. Indexed amounts are provided for tax credits, medical expense supplements, old age security
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Peru simplifies tax residency certification with new resolution
Peru has introduced Resolution No. 000141-2024/SUNAT, published in the Official Gazette on 14 July 2024, updated to the procedures governing residence certificates for tax treaty applications. This resolution amends the existing Resolution No.
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Hungary, US: CbCR agreement comes into force
The Hungary-United States Agreement on the Automatic Exchange of Country-by-Country Reports (CbCR) (2024) came into effect on 25 November 2024. The newly approved agreement will succeed the 2018 IGA which ended on 8 January 2023. Earlier,
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US: IRS and Treasury propose rules on taxed earnings, basis adjustments
The US Internal Revenue Service (IRS) and Treasury Department have issued proposed regulations (REG-105479-18) on 2 December 2024, addressing previously taxed earnings and profits (PTEP) of foreign corporations and the associated basis
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Argentina scraps advance PAIS tax on imports
Argentina’s tax authority (ARCA) has announced that it eliminated the 95% advance payments of the PAIS tax (Impuesto Para una Argentina Inclusiva y Solidaria) on foreign currency purchases for imports, effective 25 November 2024. This is
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Cyprus confirms CbC exchange effective date with US, filing obligations
The Cyprus Tax Department has issued a notice on 19 November 2024, outlining the anticipated effective date for the agreement on exchanging Country-by-Country (CbC) reports with the US as well as related local filing requirements. The Cyprus Tax
See MoreUS: Congressional Research Service updates report on global intangible low-taxed income
The US Congressional Research Service (CRS) has released an updated report (IF 11943) addressing proposed changes to the taxation of global intangible low-taxed income (GILTI) on 25 November 2024. The updates explain that the proposed changes
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Guatemala proposes simplified tax plans for handicrafts, agriculture
Guatemala’s Congress has passed Decree 31-2024, which includes “The Law for the Integration of the Primary and Agricultural Sector,” on 19 November 2024. This proposal shall establish two streamlined special tax regimes: The production and
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Costa Rica sets new interest rate for taxes and customs
Costa Rica’s General Directorate of Finance (DGH) and the General Directorate of Customs (DGA) released Resolution MH-DGH-RES-0054-2024/MH-DGA-RES-1817-2024 which establishes a new interest rate of 8.43% applicable to tax and customs
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US: IRS provides transitional relief for payment app transactions
The US Internal Revenue Service has issued Notice 2024-85 corresponding to a news release (IR-2024-299) on 26 November 2024, providing transition relief for third-party settlement organisations (TPSOs), also known as payment apps and online
See MoreArgentina announces new interest rates for late tax payments
Argentina’s Federal Tax Authority (ARCA) announced the new interest rates in Auction Rate Securities (ARS) applicable to late tax payments for the period from 1 December 2024 to 31 January 2025. The rates have been calculated in accordance with
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Colombia consults new tax haven list
The Ministry of Finance in Colombia has released a draft decree for public consultation, proposing a new list of 25 jurisdictions classified as non-cooperative due to their low or zero taxation (commonly referred to as tax havens). The deadline
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Brazil proposes income tax reform, plans spending cuts
Brazil’s Finance Minister Fernando Haddad has proposed expanding income tax exemptions for lower-income citizens while increasing taxes on higher earners on 27 November 2024. Alongside these measures, the Finance Minister also outlined plans to
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Brazil consults commodity transfer pricing
Brazil's revenue authority has launched a public consultation on a proposed amendment to its transfer pricing rules on 27 November 2024. The proposed amendment concerns Normative Instruction RFB No. 2,161 of September 28, 2023, addressing
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El Salvador launches ‘Inspectores Fiscales Sin Fronteras’ programme to combat tax evasion
El Salvador’s Ministry of Finance has launched the "Inspectores Fiscales Sin Fronteras" programme to improve tax auditing and criminal investigations, focusing on Transfer Pricing and Tax Crime Investigation. The initiative aims to strengthen
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Chile revises VAT registration, payment rules for non-resident service providers
Chile’s tax authority (SII) has recently issued Resolution No. 105 on 30 October 2024 and Resolution No. 107 on 14 November 2024. These resolutions update the previous regulations regarding VAT registration and payment for non-resident
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