Peru: SUNAT publishes new tax guidance on indirect transfers for entities
On 4 June 2019, the Peruvian tax authority (SUNAT) published new guidance (Informe No. 046-2019-SUNAT/7T0000) for the determination of the market value of shares in relation to the rules for the taxation of the indirect transfers of shares in
See MorePanama updates form for related-party transactions
In Panama, an information return (Form 930) on the transactions conducted with related parties resident abroad should be filed within six months of the close of the fiscal year. The taxpayers, whose transactions with related parties that took place
See MoreArgentina modifies TP documentation requirements
On 27 May 2019, the Federal Administration of Public Revenue (AFIP) has published General Resolution 4496 (GR 4496) in the official gazette amending General Resolution 1122 (GR 1122). The resolution explains requirements, deadline, thresholds for
See MoreArgentina issues decree regarding exemption to the tax on debits and credits
Argentina issued Decree No. 373/2019 on 27 May 2019, which includes new exemption from tax on debits and credits for those accounts used for the provision of financial services by complementary financial services agencies. The decree was issued
See MorePuerto Rico proposes tax incentives for qualifying Opportunity Zones
On 14 May 2019, Governor of Puerto Rico signed the Senate Bill 1147 (the Opportunity Zones Development Act), offering tax incentives for investments in qualifying Opportunity Zones. The act permits the investors following benefits: The new act
See MoreBrazil publishes general rules regarding shareholder interest on net equity
On 6 May 2019, Brazil has published general rules 7018 of 21 March 2019 in the official gazette clarifying calculation and deduction of interest on net equity. The calculation will take into account for the following equity
See MoreArgentina implements new rules for withholding tax on dividends
On 9 May 2019, Argentina has published General Resolution 4478/2019 in the official gazette amending the withholding tax rates on dividends. The new rules explain the following measures: Retention Procedures Generally, the withholding tax is
See MorePeru: SUNAT issues a new transfer pricing guideline on related-party share transfers
On 16 May 2019, Peruvian tax administration published a guidance “Informe No. 057-2019-SUNAT/7T0000” outlining the tax treatment of transfers of undervalued Peruvian entity shares involving foreign related parties. Under this any transfer
See MorePeru publishes conditions and procedures to implement GAAR
On 6 May 2019, the Peruvian Minister of Economic issued a Supreme Decree 145-2019-EF, which contains the provisions for the Peruvian General Tax Avoidance Scheme (GAAR) for tax purposes, which allow the Peruvian tax administration to prevent tax
See MoreColombia: DIAN simplifies the scope of new thin capitalization rule
On 5 April 2019, the tax Authority (DIAN) of Colombia published an opinion No. 8159, concerning the scope of the thin capitalization rule, ratification with the Financing Law (Law 1943 of 2018). Accordingly, as from taxable year 2019, the thin
See MoreMexico publishes Annexes to Miscellaneous Tax Resolution 2019
On 29 April 2019, Annexes of the Miscellaneous Tax Resolution for fiscal year 2019 (Resolución Miscelánea Fiscal para 2019, RMF 2019) were published in the Official Gazette published. The location of the administrative units of the Tax
See MorePeru: SUNAT issues a rule on Interest paid on loans from related parties
On 23 April 2019, the Tax Administration (SUNAT) of Peru issued Administrative rule 033-2019-SUNAT/7T0000 regarding the application of the Peruvian thin capitalization rules which specify a restriction of the deduction of interest on loans where a
See MorePuerto Rico publishes Circular regarding new quarterly tax return for withholding Payments for services provided
On 4 April 2019, the Puerto Rican Department of Treasury issued a Circular Letter No. 19-10Â regarding new quarterly tax return for withholding Payments for services provided, using a new quarterly return form(Form 480.6 SP-1). The
See MoreColombia publishes a decree on deadline of tax filing returns and tax payment for 2019
On 8 April 2019, Colombia issued Decree 608 of 2019 in the Official Gazette that provides rules on the filing of returns for the net worth tax between 26 September 2019 and 9 October 2019, depending on the last digit of the Tax Identification
See MoreMexico: Tax Administration issues new incentive for interest on corporate debt bonds
On 29 April 2019, the Mexican Tax Administration (SAT) in its Official Gazette published the Miscellaneous Tax Code (MTR) of 2019. Accordingly, the regulations grants special tax incentive decree for interest on corporate debt bonds. The
See MoreMexico: Tax Administration Service publishes Q&As with respect to transfer pricing comparability adjustments
On 29 March 2019, the Mexican Tax Administration Service published, on its website, frequently asked questions (Q&As) regarding transfer prices with respect to comparability adjustments. However, 15 January 2019 in Mexico City Government
See MoreEcuador: SRI issues circular regarding income tax law
On 9 April 2019, Ecuador’s Internal Revenue Service (SRI) issued Circular No. NAC-DGECCGC19-00000003. The circular makes a reminder about the application of the legal regulations in force for the determination of income tax for the fiscal year
See MoreDominican Republic presents fiscal transparency bill to House of Representatives
On 19 March 2019, Dominican Republic’s Committee of Public Finance proposed a bill on fiscal transparency in the House of Representatives. The main purpose of this bill is to public disclosure of high quality fiscal data & information
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