Bolivia grants extension for submitting corporate income tax reporting requirements
On 28 April 2022, the Bolivian National Tax Service published a Resolution No. 102300000014 extending the corporate income tax (IUE) reporting deadline for the tax year ending 31 December 2022 to 31 May 2023 for (i) financial statements; (ii) annual
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Peru extends income tax exemption for certain non-profit entities until 31 December 2026
On 22 April 2023, Peru issued Legislative Decree No. 1549 in the Official Gazette, which extends the income tax exemption provided by Article 19 of the Income Tax Act for certain non-profit entities. Accordingly, the income tax exemptions, which
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US: IRS releases interim guidance on review and acceptance of APA submissions
On 25 April 2023, the Internal Revenue Service (IRS) published a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International Division (LB&I) with respect
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Panama extends ‘Large Taxpayer’ definition
The Directorate General of Revenue (DGI) of Panama released Resolution No. 201-3346 on 13 April 2023. On 19 April 2023, this resolution has been published in Official Gazette No. 29764, and effective since that date. The resolution revises the
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US: IRS issues interim guidance on review and acceptance of advance pricing agreement (APA) submissions
The Internal Revenue Service (IRS) Large Business and International (LB&I) division released a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International
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El Salvador: Parliament approves law for the promotion of technological manufacturing and innovation
On 19 April 2023, the Legislative Assembly approved a law for the Promotion of Technological Innovation and Manufacturing with 69 votes in favor. The new legal law offers tax benefits to individuals or organizations, both domestic and foreign,
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Chile: Tax authority clarifies time limits for MAP requests
On 19 April 2023, Circular No. 19 was released by the Chilean tax authority. This circular modifies Circular No. 13, which was published on 18 March 2022, which provides guidance on the Mutual Agreement Procedures (MAP) under Chile’s tax treaties.
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Brazil publishes law extending certain CFC benefits
On 13 April 2023, Law No. 14.547 transposing Provisional Measure 1148/2022 into law was published in the Brazilian Official Gazette, which extends certain benefits in regard to the controlled foreign company (CFC) rules under Law 12,973/14. Under
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Canada: Tax measures in federal budget 2023
On 28 March 2023, Ms. Chrystia Freeland, the Deputy Prime Minister and Minister of Finance released Budget 2023. Canada’s economic growth was the strongest in the G7 over the last year, and today, 830,000 more Canadians are employed than before
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Brazil: Lower House passes transfer pricing reform measure
On 30 March 2023, the Brazilian Lower House of Congress adopted Measure No. 1,152 to overhaul its transfer pricing system that was introduced on 29 December 2022. In addition to introducing the arm's length principle into the Brazilian transfer
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US and Germany sign CAA regarding CbC exchange arrangement
On 24 March 2023, US and Germany signed a Competent Authority Agreement (CAA) to exchange country-by-country (CbC) reports. The Competent Authorities desire to conclude this Arrangement on the exchange of CbC Reports based on domestic reporting and
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Costa Rica extends filing deadline for inactive entities
On 29 March 2023, Costa Rica issued Resolution No. MH-DGT-RES-007-2023 providing an extension of filing annual informative return for inactive entities. Usually, inactive entities are required to file their informative return by 30 April of each
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Chile launches public consultation on MAP
The Internal Revenue Service (SII) of Chile has launched a public consultation on a draft circular that aims to clarify the 3-year deadline for submitting a mutual agreement procedure (MAP) request. The SII is accepting feedback from the public
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Mexico deposits ratification instrument for BEPS MLI
On 15 March 2023, Mexico deposited its instrument of ratification of the Multilateral Convention on the Implementation of Tax Treaty-Related Measures to Prevent BEPS (MLI). The Convention will enter into force in relation to Mexico on 1 July 2023.
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US: Tax proposals under the budget for fiscal year 2024
On 9 March 2023, U.S. President Joe Biden released the Fiscal Year 2024 Budget introducing following tax proposal. Ensures Corporations Pay Their Fair Share: The Budget includes an increase to the rate that corporations pay in taxes on their
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Brazil publishes law reducing WHT rate on cross-border payments
On 28 February 2023, the government of Brazil has published Law no. 14,537, which reduces the withholding tax rates for cross-border payments related to travel to foreign individuals or entities residing or having their registered offices
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Brazil issues normative instruction establishing new transfer pricing regulations for 2023
On 24 February 2023, the Brazilian Federal Revenue Office published the Normative Instruction No. 2.132 which establishes the regulation of the taxpayer's choice to apply the new transfer pricing rules according to Provisional Measure (PM) No.
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Colombia amends the tax return and payment deadline in 2023
On 15 February 2023, the Colombian Ministry of Finance published Decree 0219 amending the deadlines for filing and payment of the tax return (declaration) in 2023 for specific taxpayers. Some of the key deadlines for companies depend on the last
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