PGA Highlights: January 2018
In the United States the following events have taken place under the several PGA during the month of January 2018. Agencies Summary Federal Register Scheduling of upcoming public hearing: The Commission has scheduled a public hearing for March
See MorePeru: Tax authority issues ruling on deadline for submitting local file
On 18 January 2018, the Peruvian tax authorities (SUNAT) issued Ruling N° 014-2018/SUNAT requiring taxpayers to electronically submit the local file on an annual basis in June of the following year. The due date for the submission of the first
See MoreUS: IRS issues guidance on penalties for understatement of income tax
On 29 January 2018, the US Internal Revenue Service (IRS) has issued the Revenue Procedure 2018-11 to recognize circumstances under which the disclosure on a taxpayer’s income tax return with respect to an item or position is adequate for the
See MoreDominican Republic: DGII publishes TP reporting threshold for 2018
The General Directorate of Internal Taxes (DGII) published the Transfer pricing (TP) reporting threshold for 2018 on 19 January 2018. According to the DGII, the adjusted amount that will govern for 2018 corresponds to the sum of DOP 11,015,961.
See MoreGeorgia: Parliament amends the Tax Code
The Parliament approved amendments to the Tax Code which will be entering into force the moment it receives the signature of the President and receives the publication in the Official Gazette. The Parliament adopted the amendments made to the Tax
See MoreIndia: CBDT signed first bilateral APA with US
On 5 January 2018, the Indian Central Board of Direct Taxes (CBDT) signed the first bilateral advance pricing agreement (APA) with the United States. The CBDT has also indicated that there are many more bilateral APAs with the United States
See MoreBrazil publishes provisional measure on special tax regime
Brazil's provisional measure 795/2017 was turned into Law 13.586 / 2017, as published in the Official Journal of 29th December 2017. Provisional Measure 795/2017, initially released on 18th August 2017, provides for the tax treatment of exploration
See MoreUS: IRS releases directives on transfer pricing examinations
On 12 January 2018, the IRS Large Business and International (LB&I) division publicly released a set of five LB&I directives as guidance with respect for examinations of transfer pricing issues. Interim Instructions on Issuance of
See MoreUS: IRS updates information concerning country-by-country (CbC) reporting
On 18 January 2018, the IRS issued a release announcing updates and information regarding country-by-country (CbC) reporting requirements in the United States. Under the update list, IRS publishes new content on Country-by-Country (CbC) reporting
See MoreUS: Government signs joint statement on exchange of country-by-country tax reports with France
On January 12, the IRS announced on its website that the US and French competent authorities would like to sign a joint statement to spontaneously exchange CbC reports submitted by their respective taxpayers. The Competent Authorities desire to
See MoreUS: IRS issues additional guidance for computing the “transition tax” on foreign earnings
On 19 January 2018, the Treasury Department and the Internal Revenue Service issued additional guidance (Notice 2018-13) for computing the “transition tax” on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax
See MoreJamaica: TAJ revised the income tax return forms and due date
Tax Administration Jamaica wishes to advise that the deadline to file Final Income Tax Returns forms for the year of assessment 2017 has been extended until 15 March 2018. TAJ also stated that the revisions are improvements which will allow the
See MoreEcuador reforms tax law for 2018
On 29 November 2017, Ecuador has enacted a new law published in Official Gazette-150 that reforms tax laws, effective as of 1 January 2018. Corporate income tax The new law increases the corporate income tax rate from 22% to 25% and withholding
See MoreArgentina: AFIP publishes a Resolution to amend rules on capital gains tax of nonresidents
The Argentine Tax Authorities (“AFIP”) published General Resolution No 4190/2018 (“GR 4190”) on January 12, 2018 in the Official Gazette and issued it on January 11, 2018. As a result of the recent tax reform enacted through Law 27,430, a
See MoreCanada: Trade complaint files against US
Canada filed an official request for consultations document, which was circulated on January 10, 2018, to other World Trade Organization (WTO) members concerning certain laws, regulations and other measures maintained by the US with respect to
See MoreColombia issues regulations on CbC reporting notification requirement
The tax authority of Colombia (DIAN) published Decree 2120 of 15 December 2017 concerning the obligation for taxpayers to inform the tax authorities whether they are required to file the Country-by-Country (CbC) report. The CbC report filing
See MoreUS: IRS issues guidance for computing the “transition tax” on foreign earnings
On 29 December 2017, the Treasury Department and the Internal Revenue Service issued Notice 2018-07, which provides guidance for computing the “transition tax” under recent tax legislation enacted on Dec. 22, 2017. In general, newly-issued
See MoreUS: The Nation’s tax season will begin 29 January 2018
On January 4, 2018, the Internal Revenue Service announced that tax collection will begin on Monday, January 29, 2018, and taxpayers are reminded of certain tax credits that the refunds will not be available until the end of February. The IRS will
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