Dominican Republic: DGII describes a guide regarding FTC
The Tax Authority has recently made a clarification through a Public Ruling, GLN 25641, regarding foreign tax credit (FTC) as well as unilateral relief methods. According to the letters, the maximum foreign income tax credit paid to a foreign
See MoreUS: IRS releases interest rates on overpaid and underpaid tax for Q1 of 2022
On 23 November 2021, the Internal Revenue Service announced that interest rates will remain the same for the calendar quarter beginning January 1, 2022. The rates will be: 3% for overpayments (two (2) percent in the case of a corporation),0.5%
See MoreMexico: Congress approves Economic Package for the fiscal year 2022
On 26 October 2021, Mexican Congress has approved the tax reform for 2020 which was presented for the fiscal year 2022 which was presented on 8 September 2021. The Economic Package clarifies income tax law, value-added tax (VAT) law, excise tax
See MoreColombia reduces interest and penalties in response to COVID-19
On 29 October 2021, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales-DIAN) has issued Resolution No. 000126, through which DIAN has temporarily reduced penalties to 20% and a default interest rate of 20% of the
See MoreColombia issues Draft Resolution to set UVT for 2022
On 8 November 2021, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales-DIAN) has issued a Draft Resolution to set out the tax unit value (Unidad de Valor Tributario – UVT) applicable for the year 2022. The UVT is
See MoreColombia: Government issues regulations identifying preferential tax regimes
On 28 October 2021, the Colombian Government has issued Decree 1357, through which it partially regulates article 260-7 of the Tax Code. The Decree identifies criteria to consider a jurisdiction as a Preferential Tax Regime. This decree was
See MorePeru: Government submits Tax Reform Bill to Congress
On 27 October 2021, the Government led by President Pedro Castillo has submitted a bill to Congress through which it requests extraordinary powers to legislate on tax matters. The main measures of the Bill are as follows: Increase of capital
See MoreDominican Republic: DGII describes a guide on foreign tax credit
The Tax Authority has recently made a clarification through a guide, GLN 25641, regarding foreign tax credit (FTC) as well as unilateral relief methods. The following instructions are effective immediately and have included in the Tax Code: The
See MoreDominican Republic: Government establishes thresholds and filing obligation of CbC report
On 5 October 2021, the Government established specific regulations for the country-by-country report through general standard on August 2021. The general rule is aligned with the model legislation included in the OECD’s base erosion and profit
See MoreBrazil: STF decides that interest on late tax refunds is non-taxable
On 24 September 2021, the Federal Supreme Court (Supremo Tribunal Federal, STF), ruled Extraordinary Appeal No. 1.063.187) that certain interest that a taxpayer receives on a late tax refund from the treasury should not be included in the
See MoreEl Salvador: Legislative Assembly approves tax amnesty until 10 December
On 5 October 2021, at the request of the Ministry of Finance, the Legislative Assembly approved Legislative Decree 173 known as Tax Amnesty. The decree aims to give taxpayers 60 days to settle their situation before the Treasury, with exemption
See MoreCyprus clarifies bilateral agreement with US on exchange of CbC report
On 7 October 2021, the Cyprus Tax Department informs all legal entities 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
See MoreNamibia signs MLI tax convention
On 30 September 2021, Namibia has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, becoming the 96th jurisdiction to join the Convention. The provisional list of reservations
See MoreUS: CRS releases report on tax provisions in the “Build Back Better Act”
On 28 September 2021, the U.S. Congressional Research Services (CRS) has published a report on the tax provisions in the legislative recommendations for the budget reconciliation legislation, also known as the “Build Back Better Act. The
See MorePuerto Rico: Treasury Department clarifies guidance on transfer pricing studies
On 20 September 2021, the Puerto Rico Treasury Department (PRTD) has issued Administrative Determination (AD) No. 21-08, which amends AD No. 21-05 of 11 May 2021. The AD 21-08 clarifies guidance on submitting transfer pricing studies (TPS). AD
See MorePuerto Rico extends the due date for filing annual corporate reports for 2020
On 20 September 2021, the Puerto Rico Department of State has issued Administrative Order 2021-05, extending the due date to 22 November 2021 for filing annual corporate reports for 2020 due to the ongoing Covid-19 pandemic. Previously, taxpayers
See MoreBrazil: Senate announces to analyze tax reform Bill
On 21 September 2021, the Senate made an announcement that the Senate will analyze tax reform Bill, PL 2.337/2021 , a bill that changes the income tax rules. The Bill represents the second phase of the tax reform, which was approved by the Chamber
See MorePeru sets CbC reports ‘secondary filing’ for US parent entities located in Peru
There is no automatic exchange of country-by-country (CbC) reports agreement between Peru and the United States (US). So the US parent entities located in Peru will be required secondary filing by mid-October 2021 for the fiscal year 2020. The
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