Uruguay revises list of low tax countries
On 28 December 2022, the Uruguayan Tax Administration released Resolution No. 2470/022, which updated the list of low or no taxation countries or jurisdictions. On 29 December 2022, the Resolution was published in the Official Gazette and entered
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Panama declares CbC Reporting deadline
On 30 December 2022, the Resolution 201-9507 was published in Official Gazette No. 29692-A, that extended the deadline for submitting the country-by-country (CbC) report for fiscal year 2021 to 15 January 2023. The CbC report must be submitted
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Brazil issues new transfer pricing legislation to align with OECD transfer pricing guidelines
On 29 December 2022, the outgoing Brazilian President issued draft legislation MP 1.152 to align Brazil’s unique transfer pricing system with the OECD Transfer Pricing Guidelines. The news rule will be compulsory for 2024, for fiscal year 2023,
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Costa Rica: Ministry of Finance issues decree setting the corporate tax brackets for 2023
On 23 December 2022, the Costa Rican Ministry of Finance published Executive Decree No.43852-H updating the individual and corporate income tax thresholds for 2023. Accordingly, companies whose gross income does not exceed the amount of
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Canada releases Fall Economic Statement Implementation Act 2022
On 15 December 2022, Bill C-32, the Fall Economic Statement Implementation Act 2022, received Royal Assent in Canada. Key measures adopted in Bill C-32 to make life more affordable include: Permanently eliminating interest on Canada Student
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Colombia: Congress enacts tax reform law
On 13 December 2022, the Colombian Congress approved Law 2277 of 2022 (tax reform law) which contains changes in the current tax regime. The main tax measures of the Tax Reform Bill are as follows: Corporate Income Tax (CIT) Although the
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US: IRS publishes join statement with France on exchange of CbC reports for FY 2022-2023
On 7 December 2022, the Internal Revenue Service (IRS) published a joint statement with the competent authority of the United States of America and the competent authority of the French republic on the implementation of the spontaneous exchange of
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US: IRS publishes interest rates on overpaid and underpaid tax for Q1 of 2023
On 29 November, the Internal Revenue Service announced that interest rates will increase for the calendar quarter beginning January 1, 2023. For individuals, the rate for overpayments and underpayments will be 7% per year, compounded daily, up
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Ecuador submits a draft bill in the parliament on tax incentives for audiovisual and energy sectors
On 24 November 2022, the government of Ecuador submitted a draft bill in the National Assembly that provides incentives for audiovisual and energy sectors. The incentives include: A remittance tax exemption on expenditures occurs for carrying
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US: IRS issues guidance related foreign tax credit
On 22 November 2022, the U.S. Internal Revenue Service issued a guidance relating to the foreign tax credit, including guidance with respect to the reattribution asset rule for purposes of allocating and apportioning foreign taxes, the cost recovery
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Germany publishes a draft bill updating list of participating jurisdictions under MCAA-CbC
On 23 November 2023, the German Ministry of Finance published a draft bill providing an updated list of jurisdictions participating under the Multilateral Competent Authority Agreement (MCAA) on the exchange of CbC reports. Accordingly, Germany will
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Mexico ratifies BEPS multilateral convention
On 22 November 2022, the Mexican President approved a Decree for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Mexico signed the MLI on 7 June 2017. Mexico
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Argentina: Commission on foreign affairs endorses a bill to ratify MLI
On 8 November 2022, the Argentine Commission on Foreign Affairs accepted a bill to ratify the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). On 7 June 2017, Argentina signed the MLI containing a
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Costa Rica extends the deadline for filing informative returns for dormant companies
On 9 November 2022, Costa Rica published the Resolution No.DGT-R-033-2022 regarding further extension of deadline for filing informative returns for dormant companies. This is the third extension of the filing deadline. Previously, it was extended
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Germany: Federal Cabinet approves CbC reports exchange agreement with US
On 4 November 2022, the German Upper House of Parliament (Bundesrat) approves bill No. 567/22 for consideration to ratify the competent authority agreement (CAA) on the exchange of country-by-country (CbC) reports with the US. The competent
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Cyprus: Clarification Bilateral Agreement for exchange of CbC between Cyprus and the USA
On 13 October 2022, the Cyprus tax authority informed all legal entries and their representatives that the bilateral Competent Authority Arrangement (CAA) for the exchange of Country-by-Country (CbC Reports) between Cyprus and the United States of
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Mexico: Senate approves BEPS MLI
On 12 October 2022, the Mexican Senate approved the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Mexico signed the MLI on 7 June 2017. Mexico must now deposit its ratification
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Colombia: Congress approved Tax Reform Bill in the first debate
On 6 October 2022, the Colombian Congress approved Tax Reform Bill in the first debate. The Bill was presented to Congress on 8 August 2022. After the final approval of the Bill, the changes will become effective as of 1 January 2023. The main tax
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