The Press Room

Author: Isabel Martinez

Brazil’s new transfer pricing rules

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

Amounts Required for Transfer Pricing Report Submission in Ecuador

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

NewsFlash August 2023

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

Unpacking Pillar One, Amount B from a Transfer Pricing Perspective

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

NewsFlash July 2023

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

Mexico – Country Profile by the OECD

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

NewsFlash – June 2023

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

Exciting News: Brazil Enacts Long Awaited OECD Transfer Pricing Rules!

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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