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
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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
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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 MoreUS: 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
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Mexico: BEPS MLI enters into force
On 3 July 2023, OECD published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, MLI entered into force for
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OECD: Tax Transparency In Latin America 2023
On 27 June 2023 the OECD published Tax Transparency in Latin America 2023, during the latest meeting of the Punta del Este initiative. The Punta del Este Declaration aimed to tackle tax evasion and avoidance and other financial crimes by promoting
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Panama extends deadline for transfer pricing return
On 26 June 2023, the Panamanian tax authority issued Resolution No. 201-5949, that announced an extension of the deadline for calendar year taxpayers to file transfer pricing return (Form 930) for fiscal year (FY) 2022. The original deadline of 30
See MoreUS: IRS issues guidance for the advanced manufacturing investment credit
On 14 June 2023, the Internal Revenue Service issued proposed regulations that provide guidance regarding the implementation of the elective payment provisions of the Advanced Manufacturing Investment Credit, established by the Creating Helpful
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Argentina: AFIP introduces new payment facility for outstanding tax on SMEs
On 17 May 2023, Argentine tax authority (AFIP) has published General Resolution No. 5361/2023 which introduce a new payment facility for outstanding tax, social security, and customs obligations due until 30 April 2023, containing related interest
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Brazil: President signs OECD-aligned transfer pricing rules
On 14 June 2023, the president Luiz Inácio Lula da Silva signed the Law No. 14,596 adopting Provisional Measure No. 1,152, which enacts significant changes to the Brazilian transfer pricing system that is aligned with the guidelines provided by the
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Chile extends deadline for transfer pricing returns
On 20 June 2023, the Chilean tax authority (SII) issued Resolution No. 70 that provides an extension of three months to taxpayers who were required to submit their transfer pricing returns between 1 July 2023 and 30 September 2023. The extension
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US: Connecticut extends corporate surcharge under the budget bill 2024
On 12 June 2023, Connecticut Governor Ned Lamont of USA signed the budget bill (H.B. 6941) which includes an extension of the corporation business tax (CBT) surcharge for three years. The surcharge, set at a rate of 10%, applies to companies with
See MoreUS: IRS grants penalty relief for corporate alternative minimum tax
On 7 June 2023, the Department of Treasury and the Internal Revenue Service issued Notice 2023-42, which will grant penalty relief for corporations that did not pay estimated tax in connection with the new corporate alternative minimum tax
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Canada releases consultation paper on reforming transfer pricing rules
On 6 June 2023, the Canadian Department of Finance issued a consultation paper on reforming and enhancing Transfer Pricing Rules. Budget 2021 announced the government’s intention to consult on Canada’s transfer pricing rules with a view of
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Mexico announces tax incentives for investment in Interoceanic Corridor’s development hubs
On 5 June 2023, the Government of Mexico announced a decree introducing tax incentives for companies that decide to invest in Interoceanic Corridor’s development hubs. The decree aims to promote economic development in the disadvantaged southeast
See MoreUS: IRS publishes interest rates remain the same for the third quarter of 2023
On 22 May 2023, the U.S Internal Revenue Service announced that interest rates for overpaid and underpaid tax for the calendar quarter beginning 1 July 2023, which will remain unchanged from the second quarter. For individuals, the rate for
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Costa Rica: Legislative Assembly adopts a bill to introduce income tax law
On 18 May 2023, the Costa Rican National Legislative Assembly approved Bill No. 23760, which aims to introduce a new Income Tax Law. The bill proposes to repeal the existing corporate income tax law, Law No. 7092 of 1988. Instead, it suggests
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Venezuela increases tax unit value for 2023
On 8 May 2023, the National Integrated Service of Customs and Tax Administration (SENIAT) of Venezuela published Administrative Ruling SNAT/2023/000031 in the Official Gazette, which increases the value of tax units from VES 0.40 to VES 9.00 for the
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