US: IRS evaluating group membership to fix arm’s length interest rate
On 29 December 2023, the Office of Chief Counsel Memorandum announced that the IRS is considering group membership to determine the arm's length interest rate chargeable for intragroup loans and make a section 482 adjustment. The memorandum provides
See More
Chile releases 8th catalog of tax schemes
On 27 December 2023, Chile’s tax authority declared it published the eighth version of the Catalog of Tax Schemes. The publication of this Catalog responds to the challenge of ensuring that each taxpayer understands compliance with their tax
See More
Peru updates tax code on interest for refunds and penalties
On 20 December 2023, Peru’s Congress announced it amended its tax code concerning Law 31962. The amendment is related to the interest rate that the Tax Authority should consider involving cases on refund claims for improper or excessive tax
See More
Canada mulls tax credits for clean hydrogen and tech manufacturing
On 20 December 2023, Canada's Department of Finance launched consultations on introducing tax credits for clean hydrogen investment and Clean Technology Manufacturing investment. As detailed in the 2023 Fall Economic Statement, the government is
See More
Brazil passes major indirect tax reforms
On 20 December 2023, Brazil passed Constitutional Amendment No. 132 of 20 December 2023, introducing major indirect tax reforms. These reforms will replace or unify several existing indirect taxes with new tax measures. The taxes that are
See More
Argentina issuing bonds for state reconstruction
On 22 December 2023, the Argentine government issued Decree No. 72/2023 concerning the Bonds for the Reconstruction for a Free Argentina or Bonos para la Reconstruccion de una Argentina Libre (BOPREAL). The Argentine Central Bank will issue BOPREAL
See More
Colombia announces new TP documentation deadlines for 2023 and later
On 22 December 2023, Columbia released Decree 2229, introducing revised deadlines for submitting various forms of transfer pricing documentation. These include the informative declaration, country-by-country (CbC) notification, Local file, Master
See More
US: IRS declares new penalty relief for taxpayers for 2020 and 2021 tax returns
On 19 December 2023, the U.S. IRS declared it is providing new penalty relief for approximately 4.7 million individuals, businesses, and tax-exempt organizations that were not sent automated collection reminder notices during the pandemic. The
See MoreUS: IRS releases draft form for corporate AMT
The U.S. IRS has released the draft Form 4626 - Alternative Minimum Tax—Corporations concerning Corporate Alternative Minimum Tax (CAMT), The Inflation Reduction Act introduced CAMT, which enforces a minimum tax of 15% on the adjusted financial
See MoreUS Treasury signs income tax treaty with Chile
On 19 December 2023, the U.S. Department of the Treasury announced the entry into force of a comprehensive income tax treaty between the United States and Chile. The Chile tax treaty is the first new comprehensive bilateral tax treaty signed by the
See MoreArgentina: AFIP raises foreign currency tax for imports & freight
On 13 December 2023, Argentina’s tax authority (AFIP) declared that it had increased the tax on foreign currency purchases (PAIS tax) from 7.5% to 17.5%. This tax rate is applied to the purchase of foreign currency for the payment of import
See More
US: IRS publishes guidance regarding the foreign tax credit and dual consolidated losses in relation to the GloBE model rules
The U.S. IRS has published Notice 2023-80, which outlines the guidance regarding the foreign tax credit and dual consolidated losses in relation to the GloBE Model Rules. The Notice also includes the Extension and Modification of the Temporary
See More
El Salvador: Congress extends tax amnesty until December 2023
El Salvador’s Congress has passed a tax amnesty, which is open to taxpayers only until 31 December 2023 and permits regularizing monthly and/or annual obligations (including customs) arising until September 2023. Legislative Decree No. 875
See More
Brazil tax reform brings challenges to service sectors
The new Brazilian transfer pricing rules align with the OECD standard and are a radical change to the analysis of intra-group transactions, and offer several implementational challenges. Besides, the tax reform (PEC 45/2019) is being discussed in
See MoreArgentina: Newly elected government announces tax reforms
On 10 December 2023, the recently elected Government took power and has announced a series of structural economic and tax measures, including a significant simplification and reduction in applicable taxes. One of the measures announced has been
See More
Costa Rica announces CIT brackets for 2024
On 7 December 2023, the Ministry of Finance of Costa Rica published Executive Decree No. 44276-H in the Official Gazette, outlining the corporate and individual income tax brackets and rates for 2024. The updated corporate income tax is set at
See More
Ecuador releases updated technical sheet for standardizing the analysis of transfer pricing
On 22 November 2023, the Ecuadorian Tax Authority released a new edition of the technical sheet for the standardization of transfer pricing analysis, effective for fiscal year 2023. This updated document introduces significant changes to filing
See More
Ecuador introduces tax reform bill aimed at boosting foreign investment
On 28 November 2023, newly elected President of Ecuador, Mr. Daniel Noboa proposed a tax reform bill designed to attract foreign investment and boost the economy. The key proposals of the bill are as follows: The special economic development
See More