Israel deposits its MLI Ratification Instrument
The Organization for Economic Co-operation and Development (OECD) announced on September 13, 2018 that Israel deposited its instrument of ratification to implement the Multilateral Convention to Implement Tax Treaty Related Measures for preventing
See MoreDominican Republic joins BEPS inclusive framework
On 8 October 2018, the OECD announced that The Dominican Republic joined the Inclusive Framework on BEPS. As a member of the Inclusive Framework on BEPS, Dominican Republic will monitor implementation of the following four BEPS minimum standards:
See MoreEl Salvador: DGII updates transfer pricing information return and guidelines
On 1 October 2018, the Tax Authority (General Office of Internal Revenue ) updated the new version of the “Report on Operations with Related Parties (Form F-982v4),” whose method of filing is now changed from manual filing to online filing and
See MorePeru introduces GAAR, new thin capitalization rule, definition of PE, and Other Changes
On 13 September 2018, the Peruvian government has published Legislative Decree No. 1422 and Legislative Decree No. 1424, which include measures for the implementation of the General Anti-Avoidance Rule (GAAR), new thin capitalization and interest
See MoreUS: IRS proposes to withdraw section 385 documentation regulations
On 21 September 2018, IRS published a document proposing to remove Section 385 from treasury regulation that was finalized in the last of the 2016. The regulations require multinationals that issue related-party debt to provide information to the
See MoreUS: IRS issues reminders relating to Form 8975 of CbC reporting
On 18 September 2018, IRS published a release reminding MNE groups on the processes of filing country-by-country reports on Form 8975. Reminder to U.S. MNEs Filing Form 8975 with no U.S. Schedule A (Form 8975) When submitting Form 8975 and Schedules
See MorePeru: Added new thin Capitalization Rules and Amended Income Tax Law
Peru’s President enacted Legislative Decree 1424 on 13 September 2018, which amends the income tax law with regard to the thin capitalization rules, the indirect transfer of shares, the definition of permanent establishment (PE) and the indirect
See MoreUS: IRS publishes draft form regarding the “base erosion and anti-abuse tax” (BEAT)
On 5 September 2018, the United States (US) Treasury and the Internal Revenue Service (IRS) released a draft of Form 8991 concerning the “base erosion and anti-abuse tax” (BEAT) reporting for 2018. In an effort to " level the playing field
See MoreBrazil: Administrative Council of Tax Appeals approves validity of resale price method (PRL 60)
The Administrative Council of Tax Appeals (CARF) issued binding decision 115 (Súmula no. 115) on 11 September 2018. The new decision approving that, the calculation method of the ' 60% Profit Price Less Profit Method (PRL 60)' provided for in
See MoreMexico: Tax authority updates the transfer pricing adjustment rules
Recently, the Mexican tax authorities issued the Second Resolution of modifications to the 2018 Miscellaneous Tax Resolution (MTR) in which the rules regarding transfer pricing adjustments were amended and certain additional provisions were
See MoreBrazil: RFB clarifies Transfer pricing rules on import of products
On 30 august 2018, the Department of Federal Revenue of Brazil (RFB) published a ‘Private Ruling 95/2018’ in the Official Gazette which clarifies the calculation of price parameter on import of steel product for resale. Under this Private Ruling
See MoreUnited States: ADD/CVD Roundup for September 2018
Following table shows the Federal Register notices related to ADD/CVD cases for August 2018 in United States. Country Product Investigations Case Number Details Belgium Carbon and Alloy Steel Cut-To-Length Plate Initiation of Antidumping Duty
See MoreColombia updates late payment interest rate for September 2018
According to an Administrative Regulation 1112 of 2018, the effective monthly interest rate for late payment of taxes has been set at 27.72% and valid from 1 to 30 September
See MoreChile: 2018 tax reform submits to Congress
The Finance Minister, Felipe Larraín, announced on August 23, 2018, that the draft law for the modernization of taxation was submitted to Congress. It includes modification in the tax system to inspire growth, entrepreneurship, investment, savings,
See MoreU.S. and Austria sign an agreement on the exchange of country-by-country reports
According to an IRS announcement on its website, the competent authorities of U.S. and Austria have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of country-by-country
See MoreColombia: Radical Change party submits a tax reform bill to Congress
The Radical Change party, a political party of Colombia submitted a tax reform bill to Congress. The bill contains following proposals: Tax residence The bill would eliminate the requirement to base a company’s tax residence on the company’s
See MoreBrazil modifies fines applicable for companies under special regime and exempt entities
Normative Instruction 1,821/2018, published in the Official Gazette of 31 July 2018, modifies the fines applicable to companies taxed under the presumed or determined profit regime and exempt entities as follows: 5% of the gross income in case
See MoreBrazil: Mixed commission approves Provisional Measure 836/2018
The mixed commission of the Senate and Chamber of Deputies approved the conversion into law of Provisional Measure 836/2018 on 14 August 2018, which will effects from 1st September 2018. The measure still needs to be approved by the plenary of both
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