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Peru: SUNAT Regulation on Export and Import Prices: Implications and Penalties

Introduction  According to the Income Tax Law, in export or import intercompany transactions involving goods quoted on international, local, or destination markets—including derivative financial instruments—or whose prices are set based on such quotations, the taxpayer must submit a notification (sworn statement) by

The End of OECD’s Pillar I and Pillar II?

The recently issued memorandum for the Secretary of the Treasury addressing the OECD Global Tax Deal signals a major shift in U.S. tax policy, with significant geopolitical implications. Here’s a quick breakdown of the key aspects: -No Binding Effect Without Congress: Commitments

Chile Tax Compliance Bill

Last September, after passing through the Chamber of Deputies and the Senate, the so-called “Tax Obligations Compliance Project” (Bulletin 16621-05) was approved. Among the various points that the project includes/modifies within the framework of transfer pricing and mutational economic groups, we can

Unpacking Pillar One, Amount B from a Transfer Pricing Perspective

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 the proper allocation of

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