Brazil gazettes provisional measure for the taxation of investments in investment funds
On 28 August 2023, Brazil published Provisional Measure No. 1,184 (MP) outlining the taxation of investment funds in Brazil and introducing a periodic taxation approach for both closed-end and exclusive funds. Key proposals under the MP are
See More
Venezuela sets up four new special economic zones with tax benefits
On 10 August 2023, Venezuela published Decree Nos. 4,838; 4,839; 4,840; and 4,841 in the Official Gazette. The Decrees established four new special economic zones (SEZs) with tax incentives aimed at boosting production, especially for exports. The
See More
Anguilla suspends exchange of tax information with Russia and Belarus
On 21 August 2023, the Government of Anguilla announced the suspension of exchanges and the sharing of tax information with Russia and Belarus in solidarity with the United Kingdom (UK) Government. Tax information is exchanged as part of a
See More
US: IRS publishes interest rates for the fourth quarter of 2023
On 25 August 2023, the U.S. Internal Revenue Service announced the interest rates for overpaid and underpaid taxes for the fourth quarter of 2023. Accordingly, the interest rates will increase for the calendar quarter beginning 1 October
See More
US: IRS launches paperless processing initiative
On 18 August 2023, the Internal Revenue Service (IRS) announced its initiative to launch a paperless process for filing tax returns. IRS states that taxpayers will have the option to go paperless for IRS correspondence by 2024 filing season, IRS to
See More
Canada updates electronic filing requirements for business entities
On 16 August 2023, the Canada Revenue Agency (CRA) announced that businesses filing six or more information returns must file them electronically to avoid penalties. Recent legislation has amended mandatory electronic filing thresholds.
See More
Canada releases revised draft DST Act for public comments
On 4 August 2023, the Department of Finance Canada published a revised draft of the Digital Services Tax (DST) Act for public consultation. These legislative proposals would implement the Digital Services Tax Act. The Act would impose a tax
See More
Paraguay upgrades transfer pricing documentation process
On 20 July 2023, the tax authority of Paraguay (SET) issued General Resolution No. 134 of 18 July 2023, that introduces an exceptional mechanism for the submission of the technical transfer pricing study (Estudio Técnico de Precios de Transferencia
See More
Canada releases draft Global Minimum Tax Act for public comments
On 4 August 2023, Canada issued draft legislation aimed at implementing the "Pillar Two" global minimum tax framework established by the Organisation for Economic Co-operation and Development (OECD) and the G-20 Inclusive Framework on Base Erosion
See More
WTO: World Trade Statistical Review 2023
On 31 July 2023 the WTO published the World Trade Statistical Review 2023. The report looks at the patterns of world trade in 2022 and gives some insights into the outlook for 2023. The regularly updated statistics on world trade provide a
See More
IMF Report looks at the Economy of Brazil
On 31 July 2023 the IMF issued a report following talks with Brazil under Article IV of the IMF’s articles of agreement. Although economic growth in the first part of 2023 has been buoyed by strong agricultural output, manufacturing and
See More
US: final regulations on carryback of consolidated net operating losses
On 12 July 2023, the U.S. Treasury Department and IRS released final regulations in the federal register that affect corporations filing consolidated returns. These regulations permit consolidated groups that acquire new members that were members
See More
Canada plans to enact DST in 2024
On 12 July 2023, Canadian Deputy Prime Minister and Minister of Finance said “two years ago, we agreed to pause the implementation of our own Digital Services Tax (DST), in order to give time and space for negotiations on Pillar One. But we were
See More
Panama introduces updated income tax return forms
On 27 June 2023, Panama officially published Resolution No. 201-4370/2023 in the Official Gazette, that introduces updated forms for filing income tax returns. These new forms are applicable to various entities, including individual taxpayers, legal
See More
Peru shifts from LIBOR to SOFR for lower withholding tax on nonresident interest
On 29 June 2023, Peru published Supreme Decree 137-2023 in the Official Gazette for the adoption of the Secured Overnight Financing Rate (SOFR) to replace the London Interbank Offered Rate (LIBOR). The Decree came into force on 30 June 2023. This
See More
Colombia: Ministry of Finance issues draft decree on significant economic presence rule
On 30 June 2023, the Colombian Ministry of Finance issued a draft decree on the significant economic presence (SEP) rule as a part of Law 2277 of 2022 (tax reform law). The SEP rule was introduced in the context of digital services taxation. The SEP
See More
US: IRS issues practice unit on categorization of income and taxes into proper basket for FTC
On 15 May 2023, the U.S. IRS published a practice unit regarding Foreign Tax Credit - Categorization of Income and Taxes Into Proper Basket. This Practice Unit is revised to address changes from the implementation of the Tax Cuts and Jobs Act (TCJA)
See More
US: IRS publishes practice units on interest expense limitations
On 16 May 2023, the IRS Large Business and International (LB&I) division issued two practice units in relation to interest expense limitations for related party loans. Interest Expense Limitation on Related Foreign Party Loans Under IRC
See More