Today, on September 29, 2023, the Brazilian Official Gazette (DOU) published Normative Instruction RFB 2.161/23, which regulates Brazil’s new transfer pricing rules as set forth in Law 14.596/23. Important: the Normative Instruction extends the deadline for taxpayers to elect early adoption of
The Ecuadorean tax authorities, through Resolution No. NAC-DGERCGC23-00000025, have implemented significant changes regarding transfer pricing. One of the most relevant changes pertains to the minimum amounts that make submitting a transfer pricing report a requirement. According to this resolution, taxpayers subject to
Upcoming transfer pricing deadlines in the Americas Argentina: September 23 – 25 Informative Affidavit F.2668 and Local Report F.4501 for companies with a Fiscal Year End 03/31/23. Master File for companies with a Fiscal Year End 09/30/22. Argentina: September 29 First Notification
By Chad Martin and Ricardo Rosero, BaseFirma USA Background In late 2021, the OECD announced the preliminary design of its two-pillar approach to modernizing global taxation in the context of integrated, digitalized economies. Broadly speaking, Pillar One aimed to provide guidance on
Upcoming Transfer Pricing Due Dates in the Americas – Argentina: August 31, 2023. Second Country by Country report due for ultimate parent entities with fiscal year ending on 06/23. Argentina: Implementation of PAÍS Tax On July 24, 2023, Decree 377/2023 was published, implementing
The Paraguayan tax authority (SET) issued General Resolution No. 134/2023, with rules for submitting transfer pricing studies and documents that clarify transactions with foreign entities. In Paraguay, when a company engages in transactions with a foreign entity in a low or zero
Which mechanisms are available in Mexico to prevent and/or resolve transfer pricing disputes? Advance Pricing Agreements (Bilateral, Unilateral, Multilateral) Mutual Agreement Procedures Administrative or statutory dispute settlement/resolution processes Conclusive Agreements with the Procuraduría de la Defensa del Contribuyente (PRODECON) Transfer Pricing methods
Upcoming Transfer Pricing Deadlines in the Americas Bolivia: July 31st. Informative Statement F.601 and Local Report – industrial companies. Dominican Republic: July 31st. Master Report and Local Report – companies with Fiscal Year Ending on 09/30/22. DIOR Informative Statement – companies with
On June 20, 2023, the Chilean Internal Revenue Service (SII) issued Exempt Resolution No. 70,which extends the filing deadlines for many transfer pricing forms for up to three months. The option to extend applies to forms 1907, 1937, 1950 and 1951. The 1913 return
We want to let you know that the Brazilian president has officially endorsed Law 14,596/23, introducing significant amendments to the legislation governing corporate income tax to establish comprehensive regulations on transfer pricing. This landmark law is the approval of the Provisional Measure
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