Peru: SUNAT issues resolutions on GAAR
On 31 July 2019, the Peruvian Tax Administration (SUNAT) published two resolutions (152-2019/SUNAT and 153-2019/SUNAT) regarding general anti-avoidance rule (GAAR) in the Official Journal. The two resolutions are summarized below: Resolution
See MoreColombia: DIAN issues ruling on tax treatment of stock dividends
Recently, the Colombian National Tax Authority (DIAN) published Ruling 014495 of 6 June 2019, which sets out tax of profits in shares or stock dividend. The ruling includes the following points: Article 30 of the Tax Code (TC) provide the
See MoreCanada: Finance Department publishes draft Budget proposals for public comments
On 30 July 2019, the Finance Department published draft Budget proposals inviting comments to implement some of the remaining measures from the 2019 budget. The deadline for public comments is 7 October
See MoreEcuador introduces TP risk model
On 1 August 2019, the Inter-America Center of Tax Administration (CIAT) publishes a document on Ecuador Transfer Pricing (TP) Risk Model in its official website. The SRI of Ecuador, with the coordinated support of CIAT, the United Nations (UN), the
See MoreCosta Rica: MOF publishes draft resolution on advance pricing agreements (APA)
On 2 July 2019, the Ministry of Finance released a draft resolution providing rules on advance pricing agreements (APA) under the OECD transfer pricing guidelines. The resolution outlined the application procedures for approval, refusal, renewal
See MoreCosta Rica: Tax authority issues guidance on transfer pricing rules
On 26 June 2019, Costa Rican tax authority published the Resolution N° 41818-H in the Official Gazette that changes Income Tax Law regulation including transfer pricing obligations. The new Regulation defines persons as related persons who are
See MoreArgentina: AFIP updates resolution on advance payment of tax
On 12 July 2019, the Federal Administration of Public Revenues (AFIP) of Argentina has published General Resolution No. 4522/2019 amending several provisions of General Resolution 4034 which was issued in 2017. The resolution modifies the
See MoreColombia publishes new thin capitalization rule
On 26 June 2019, the Government of Colombia published a Decree 1146 of 2019, concerning the new thin capitalization rules which amended the previous law 1943 of 2018. The new Decree 1146 of 2019 includes the following measures: The thin
See MoreEcuador: SRI issues decree on advance income tax payments
On 5 July 2019, the Ecuadorian Internal Revenue Service (Servicio de Rentas Internas-SRI) issued Executive Decree No. 806 of 25 June 2019 in its official website. The decree introduces new schedule for advance income tax payments. The payment of
See MoreBrazil updates its blacklist removing San Marino
On 28 June 2019, The Department of Federal Revenue (RFB) of Brazil has published Normative Instructions No. 1896 of 27 June 2019 in the official gazette amending Normative Instructions Nº 1037. Through the instruction RFB removes San Marino from
See MoreBolivia issues resolution for tax certificates procedure
On 29 June 2019, Bolivian National Tax Service issued Resolution No. 101900000011 in the official website introducing procedure and requirement for certificates of tax residence, tax debt, and foreign accreditation. The resolution clarifies the
See MoreBrazil publishes new tax incentive regulation for oil and gas sector
On 17 June 2019, the Minister of Mines and Energy signed Regulation No 252, which regulates the process of setting priority projects in the oil, gas and biofuel sectors for issuing incentive debentures. The regulation will help unlock investment in
See MoreEcuador releases advance tax refund procedure for FY 2018
On 4 June 2019, the Ecuadorian Internal Revenue Service (SRI) issued Resolution No. NAC-DGERCGC19-0000022 dated 30 May 2019 concerning refund procedures for overpaid advance income tax in financial year (FY) 2018. According to the resolution,
See MoreCanada: Federal budget 2019 bill enacted
On 21 June 2019, Canada’s corporate income tax measures as included in three federal bills are deemed to be substantially enacted. The summary corporate tax measures are following: Increasing 15% tax credit for mineral
See MoreUruguay: New incentive for software development
Uruguay has published Decree No 96/2019 of 22 April 2019 amending exemption incentive for software development with effect from 1 January 2018 to comply with BEPS Action 5. The decree applies retroactively from 1 January 2018. The Decree
See MoreColombia: DIAN publishes procedures to submit the TP return, Master file, Local file and CbC report
On 22 May 2019, the Colombian tax authority (DIAN) published regulations for the submission of the Local file and Master file, the Transfer pricing (TP) return, and the Country-by-Country (CbC) report notification corresponding to the 2018 tax year
See MoreArgentina: Tax ruling on BEPS Action 5 minimum standard
On 30 May 2019, the Argentine tax authority published General Resolution No. 4497 (GR 4497/2019) in the official gazette amending the binding ruling (as established by Article 4 of Law No. 11,683) regulations, which adapts the Argentine tax
See MoreArgentina enacts law on knowledge-based economy
Argentina has published Law 27,506 in the official gazette enacting Decree No. 408/2019 , establishing promotional regime on tax benefits for the Knowledge Economy. The purpose of the law is to the promote of the country’s knowledge-based and
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