Uruguay: Parliament passes a bill on the Multilateral Instrument (MLI)

21 June, 2018

4 June 2018, the Uruguayan parliament passed the Bill for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Uruguay signed the MLI on 7 June 2017. The MLI will

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Ecuador announces new tax incentives

20 June, 2018

The National Assembly of Ecuador issues a draft bill with number of following new tax incentives: 8-year tax exemption for investments in Quito and Guayaquil; 10-year tax exemption for investments in priority activities outside of Quito and

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Brazil: Maximum tax refund reduces for exporting companies

15 June, 2018

Brazil has published Decree No. 9.393 of 30th May 2018 in the Official Gazette, which amends Decree No. 8,415, of February 27, 2015, which regulates the application of the special regime for the Reintegration of tax values ​​for exporting

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Brazilian government adopted several measures regarding incentive in certain sectors

11 June, 2018

Brazil has published Law 13.670 of 30 May 2018, which was enacted to reduce the number of activities of companies that may continue calculating the social security contributions upon gross revenues of services and/or products. The law includes a

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Chile: Tax authority publishes a Circular regarding transitional relief

06 June, 2018

The tax authority (SII) has released Circular No. 31 of 23 May 2018. It assures the transition relief provided regarding dividends paid by taxpayers under the partially integrated regime (PIS). The tax authority has also published Ordinance 470 and

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Canada: Minister tables Notice of Ways and Means Motion to implement BEPS MLI

04 June, 2018

The Finance Minister, Bill Morneau, tabled a Notice of Ways and Means Motion in the House of Commons on May 28, 2018, for formalizing the Government's intention to introduce legislation that would enact the Multilateral Convention to Implement Tax

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Argentina: Government publishes General Resolution 4245/2018

01 June, 2018

On 16 May 2018, Argentina has published a General Resolution (4245/2018 of 15 May 2018) on their official website.  The Resolution 4245 modifies the General Resolution 830/2000, which introduced  income tax withholding on particular payments made

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United States: ADD/CVD Roundup for June 2018

01 June, 2018

Following table shows the Federal Register notices related to ADD/CVD cases for May 2018 in United States. Country Product Investigations Case Number Details Austria Carbon and Alloy Steel Cut-To-Length Plate Antidumping Duty Order; Opportunity

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PGA Highlights: June 2018

01 June, 2018

In the United States the following events have taken place under the several PGA during the month of May 2018. Agencies Summary Federal Register Subsidy programs for softwood lumber and softwood lumber products: The Department of Commerce seeks

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US: IRS publishes new guideline for filing CbC reporting

29 May, 2018

On 18 May 2018, IRS released new guidance for filing the Form 8975 submitted by U.S. multinational enterprises (MNEs). When submitting Form 8975 and Schedules A (Form 8975), filers must attach at least two Schedules A (Form 8975) to the Form 8975.

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US: IRS issues new advance pricing agreement (APA) template

22 May, 2018

On May 11, 2018, the IRS’s Advance Pricing and Mutual Agreement Program (APMA) issued a new template that taxpayers must use when requesting an advance pricing agreement (APA) under Rev. Proc. 2015-41, 2015-35 I.R.B. 263 (Rev. Proc. 2015-41).

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Cayman Islands: DITC released official guidance on the CbC reporting requirements

22 May, 2018

The Cayman Islands’ Department for International Tax Cooperation (“DITC”) released their official guidance on March 29, 2018 regarding the Country-by-Country (“CbC”) reporting requirements of entities that are resident in the Cayman

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US and Indonesia sign MOU on the exchange of CbC reports

16 May, 2018

On April 26, 2018, the Internal Revenue Service issued a Memorandum of Understanding (MOU) between the Competent Authorities of the United States (US) and Indonesia, which includes an announcement of the temporary suspension of Indonesia's secondary

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Argentina: General Resolution 4227/2018 was published in official gazette

08 May, 2018

The Argentine Tax Authorities (“AFIP”) has published General Resolution 4227/2018 on April 12, 2018 in the official gazette. It is the regulation of the income tax on financial income obtained by beneficiaries abroad. This resolution was issued

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United States: ADD/CVD Roundup for April 2018

03 May, 2018

Following table shows the Federal Register notices related to ADD/CVD cases for April 2018 in United States. Country Product Investigations Case Number Details Argentina Biodiesel Antidumping Duty Orders A-357-820 See the Federal Register

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PGA Highlights: April 2018

03 May, 2018

In the United States the following events have taken place under the several PGA during the month of April 2018. Agencies Summary Federal Register Subsidy programs on cheese subject to an in-quota rate of duty: This notice provides Commerce's

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Mexico: Government declares new decrees regarding Special Economic Zones

29 April, 2018

Mexico has declared two new decrees that providing for the initiation of two new special economic zones (SEZ) in States of Campeche and Tabasco, in the official Gazette. They are designed for where they are most needed, and to boost productive

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US: IRS publishes guidance on exhaustion of administrative remedies for foreign tax credit

26 April, 2018

On 17 April 2018, IRS published a practice unit on Exhaustion of Administrative Remedies in relation to claims for a foreign tax credit. In order for a foreign tax to be creditable under Section 901, it must be compulsory. A payment is compulsory

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