Greece: Parliament adopts draft bill regarding Multilateral Competent Authority Agreement
The Greek Parliament adopted a draft bill on April 19, 2018, which ratifies the Multilateral Competent Authority Agreement between Greece and United States on the exchange of country by country (CbC) reports. The CbC report is one element of
See MorePuerto Rico: Treasury Department issues Administrative Determination regarding tax returns for 2017
The Puerto Rico Treasury Department has issued Administrative Determination No. 18-07, which determines to grant all taxpayers who file a request for automatic extension to return file for 2017, a total term of 6 months, instead of the term of 3
See MoreColombia issues ruling of CFC exemption
The tax authority of Colombia (DIAN) published a ruling regarding whether the exemption for controlled foreign company (CFC) dividend income paid out of profits from real economic activities will apply if the dividends are paid by a subsidiary of a
See MoreUS: IRS issues guidance on restriction on interest deduction
On 2 April 2018, the Treasury Department and the Internal Revenue Service (IRS) published Notice 2018-28, which provides guidance for computing the business interest expense limitation under recent tax legislation enacted on Dec. 22, 2017. In
See MoreUS: IRS issues guidance on transfer of foreign partnership interests
On 2 April 2018, the Treasury Department and the Internal Revenue Service issued guidance regarding the withholding on the transfer of non-publicly traded partnership interests under the recently enacted Tax Cuts and Jobs Act. In general, the new
See MoreUS: IRS offers guidance on ‘blended’ tax rates for corporations under the new tax reform law
On 16 April 2018, the Internal Revenue Service issued a notice that many U.S. corporations elect to use a fiscal year end instead of a calendar year end for federal income tax reporting purposes. Due to a provision in the recently enacted Tax Cuts
See MorePanama issues new form of transfer pricing information return
In accordance with Resolution No. 201-1937 of 2 April 2018, published in the Official Gazette on 9 April 2018, Panama modified Form No. 930 (V1.0), Transfer Pricing Information Return. The new form is Form No. 930
See MoreArgentina: Decree 279/2018 was published in the official gazette
The Decree 279/2018 was published on April 9, 2018 in the Official Gazette. The provisions of this decree effects from April 10, 2018. This Decree regulates the scope of the Income Tax of the financial income in order to achieve a correct
See MoreCanada: CRA issues MAP program report
The Canada Revenue Agency (CRA) issued the latest mutual agreement procedure (MAP) program report on April 13, 2018. The MAP program is a service provided by the CRA to assist taxpayers in resolving cases of double taxation or taxation not in
See MoreEl Salvador issues new Transfer Pricing Guidelines
On 21 March 2018, the General Directorate of Internal Taxes of the Ministry of Finance issued the Transfer Pricing Orientation Guide (DG-001/2018). These guideline is intended to help taxpayers to comply with the following legal obligations: The
See MoreUS: IRS publishes annual advance pricing agreement report for 2017
On 30 March 2018 with an announcement, IRS published Advance Pricing Agreement (APA) report for the calendar year 2017. The report describes the experience, structure, and activities of the APMA Program during calendar year 2017. It does not provide
See MoreUS: IRS publishes a notice concerning CbC reporting requirements of certain U.S. MNE groups
On 30 March 2018, IRS released an advance copy of Notice 2018-31 concerning national security considerations with respect to country-by-country (CbC) reporting. In consideration of the national security interests of the United States, the notice
See MoreCanada: Federal budget bill C-74 receives first reading
The Canadian federal government released first reading of Budget Implement Act (Bill C-74) on March 27, 2018. This bill includes measures from the 2018 federal budget and other measures including income tax amendments, such as, small business tax
See MoreUS: IRS issues additional guidance for computing the “transition tax” on foreign earnings
On 2 April 2018, the Treasury Department and the Internal Revenue Service published additional guidance (Notice 2018-26) for computing the “transition tax” on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax
See MoreChile: Tax authority issues Ordinances for describing dual corporate tax regimes
The tax authority has published Ordinance 470 and Ordinance 471 of 5 March 2018. It describes the application of the dual corporate tax regimes introduced as of January 1, 2017. These regimes are the standard attribution regime (AIS regime) and the
See MoreEl Salvador: Ministry of Finance publishes updated transfer pricing guidelines
On 21 March 2018, the Ministry of Finance has published the updated transfer pricing guidelines (DG-001/201). The guidelines outline the comparability analysis adjustments and adjustment information provided in the transfer pricing
See MoreUnited States: ADD/CVD Roundup for March 2018
Following table shows the Federal Register notices related to ADD/CVD cases for March 2018 in United States. Country Product Investigations Case Number Details Argentina Biodiesel Final Determination of Sales at Less Than Fair Value and Final
See MorePGA Highlights: March 2018
In the United States the following events have taken place under the several PGA during the month of March 2018. Agencies Summary CBP CBP releases E-Commerce Strategy: The U.S. Customs and Border Protection released its e-commerce strategy on
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