Colombia Sets Transfer Pricing Documentation Requirements for 2020
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January 14th, 2020
The government of Colombia published decree 2345 concerning tax regulations for natural and legal persons for the year 2020. The decree sets out the deadlines for the tax return filing and payment, as well as the deadlines for filing TP documentation.
Mexico’s Congress Approves Tax Reform 2020
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November 7th, 2019
Mexico’s congress approved, with some adjustments, the package of tax reforms for 2020 that was submitted by Mexico’s president Lopez Obrador on September 8, 2019. The final package now needs to be signed by the president, which is likely to happen shortly.
Colombia Presents New Tax Bill To Congress Following Court Ruling
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October 25th, 2019
Colombia’s Finance Ministry has submitted a tax reform bill to Congress to replace the financing law, which included income tax changes, overturned by the Constitutional Court last week.
The Constitutional Court decision .
Costa Rica Publishes List of Non-Cooperative Jurisdictions for Tax Purposes
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September 27th, 2019
The General Directorate of Taxation of the Costa Rican Ministry of Finance published a resolution on the list of non-cooperative jurisdictions for tax purposes No. DGT-R-55-2019.
Citeria for a jurisdiction to be included on the list .
CIAT Develops Risk Model For The Selection Of Transfer Pricing Audit Cases In Ecuador
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August 7th, 2019
The Inter-America Center of Tax Administration (CIAT) announced the publication of a document entitled: "Structuring of a transfer pricing risk model in Ecuador" on the structuring of a transfer pricing risk model in Ecuador, which was developed by Ecuador's tax administration (SRI) with the coordinated support of CIAT, the UN, the German Society of International Cooperation (GIZ), and the Mexican tax administration service (SAT).
The structure of Ecuador’s risk model .
Brazil Offers Tax Incentives for Companies Invest Through 'Infrastructure Debentures' In Oil And Gas Sectors
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July 30th, 2019
The Brazilian Ministry of Mines and Energy published a regulation under which companies in the oil and gas sector may claim tax incentives for foreign investments, made in priority investment projects in oil, natural gas and biofuel infrastructure areas through debentures issued by Brazilian entities established as corporations.
Details .
Newly Signed Brazil-Uruguay Tax Treaty Includes Anti-Abuse Rule
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June 18th, 2019
Brazill and Uruguay have included provisions to tackle base erosion and profit shifting in a new Double Tax Convention (DTC), signed on June 7, 2019. The new agreement incorporates the minimum standards developed by the OECD on BEPS , includes specific provisions that are intended to combat tax evasion and prevent abuse of the agreement.
Argentina Modifies Transfer Pricing Regime
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May 31st, 2019
Argentina’s Federal Administration of Public Revenues published General Resolution 4496/19, which established changes to Argentina’s transfer pricing requirements. One of the purposes of the regulation is harmonizing the filing deadlines for various transfer pricing return obligations.
Argentina Publishes New Dividend Withholding Tax Rules
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May 28th, 2019
Argentina has implemented new rules for withholding tax on dividends. The tax applies to dividend payments made to both resident individuals and nonresidents (whether legal entities or individuals).
Peru Issues New Guidance On General Anti-Avoidance Rule For Cross-Border Transactions
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May 9th, 2019
Peru has published a tax regulation clarifying the earlier General Anti Avoidance Rule (GAAR) regulation. The GAAR empowers the Peruvian tax administration to prevent tax avoidance, including tax avoidance involving cross-border transactions.
Mexico Publishes Rules On Compliance of Anti Money Laundering Obligations
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April 25th, 2019
The Mexican Tax Administration Service (SAT) published the rules on compliance of anti money laundering obligations in its official gazette.
Anti-money laundering law obligations
Latin America To Offer Solution To Tax Digital Economy
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April 16th, 2019
At an event hosted by the Inter-American Dialogue, Ubaldo González (Senior Sector Specialist in Tax Administration, Inter-American Development Bank) explained that Latin American countries face unique challenges, including revenue shortages that threaten their ability to meet the U.N.’s 2030 Agenda for Sustainable Development.
OECD Endorses Chilean Tax Reform Proposals
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March 28th, 2019
On 26 March 2019, the Minister of Finance and the head of the OECD Tax Policy Unit (the OECD) held a meeting where the OECD endorsed the tax reform proposed by the government, which is expected to be discussed in congress in the upcoming weeks, as a strategic way to promote investment and growth.
Single Corporate Tax Regime .
OECD Outlines Tax Revenues Rebound In Latin America And The Caribbean
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March 26th, 2019
The OECD launched a tax policy report outlining the rebound of tax revenue in Latin America and the Caribbean (LAC). The rebound was primarily driven by Caribbean countries and in particular Guyana and Barbados, on the back of tax policy and administration reforms.
Costa Rica Publishes Amending Resolution To Clarify CbC Reporting Requirements For Multinational Groups
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March 21st, 2019
Costa Ricas’ Government has published Resolution No. DGT-R-008-2019 in the Official Gazette. The Resolution amends Resolution DGT-R-001-2018, which regulated the information that companies based in Costa Rica need to report for the purposes of automatic exchange of country-by-country (CbC) reports in accordance with the OECD's BEPS Action 13.
How Technology Is Changing Taxation In Latin America
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March 18th, 2019
This article provides an overview of the important role played by technology in taxation and transfer pricing in Latin America, and presents comprehensive research to illustrate the digital path taken by tax administrations and corporations in Latin America and worldwide.
Given current developments in taxation, taxpayers and tax authorities face numerous challenges that result from an era of data gathering and full-transparency.
Peru Clarifies The Attribution Of Net Passive Income Of Controlled Foreign Corporations (CFC)
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February 12th, 2019
The Tax Administration ( Superintendencia Nacional de Administración Tributaria , SUNAT) published on its website Report 097-2018-SUNAT/7T0000 (the Report), clarifying the attribution of net passive income of CFC rules for its Peruvian shareholders.
CFC Rulings .
Peru - Modifications for the Regulation of the Income Tax Law
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January 24th, 2019
On the past December 30 th , 2018, Supreme Decree (SD) N° 337-2018-EF, SD N° 338-2018-EF, SD N° 339-2018-EF, and SD N° 340-2018-EF were issued. The Decrees mentioned before affect the Income Tax Law (“The Law”).
Brazil’s Stock Market Soar As New Economy Minister Vows To Slash Taxes
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January 8th, 2019
Brazil’s stock market rallied after the new economy minister, Paulo Guedes, vowed to drastically lower the country’s tax burden and reform its generous social security system, but whether those pledges will become reality remains to be seen.
Reduction of Taxes .
LATAM Ministers Devote To Combat Tax Evasion And Corruption
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November 22nd, 2018
Uruguay's Minister of Economy and Finance Danilo Astori hosted a discussion with Ministers, high level representatives and senior officials from Latin America on how to strengthen regional efforts to combat tax fraud and corruption.
Commitment .

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