NewsFlash January – 2024

Upcoming Transfer Pricing due dates  

Argentina: February 23 – 29  

  • Informative Affidavit F.2668.
  • Local Report F.4501 (Fiscal Year Ending 08/31/23). 
  • Master Report (Fiscal Year Ending 02/28/23). 

Argentina: February 29 

  • Country-by-Country Report – Fiscal Year Ending for Ultimate Parent Entity on 02/28/23. 
  • 1st notification Country-by-Country Report – Fiscal Year Ending for Ultimate Parent Entity in 11/23. 
  • 2nd notification Country-by-Country Report – Fiscal Year Ending for Ultimate Parent Entity in 12/23. 

BaseFirma Brazil Announces Team Expansion and Leadership Updates

Amidst the fast developments in the Brazilian marketplace, we are happy to announce that our team there has expanded and solidified.

José Simões is stepping into the practice leader role, and a new hire, Filipe Stalen, will be our senior associate. Jose has been involved in all the local projects for the past two years, and we feel that he has the expertise and leadership capacities to set a strong course for the Brazilian practice. Filipe previously worked in-house on transfer pricing at Mercedes Benz. To help with the transition on Davi Santana’s departure, Omar López Lopez, our Mexico practice leader, will work with the team in the coming months, to maximize the opportunities that are arising with the new OECD alignment.

We look forward to this new chapter for BaseFirma in Brazil and wish the team much success!

Chile: draft law for the registry of beneficial owners  

On December 14, 2023, the Chilean government submitted a bill to Congress proposing the creation of a National Registry of Beneficial Owners. The project indicates the persons required to register, as well as the definition of what a beneficial owner is under Chilean law. The information that must be provided for these beneficiaries includes:   

  • Names and surnames  
  • Date of birth  
  • National identity card or identity card for foreigners   
  • Nationality  
  • Address  
  • Country of residence  
  • Contact information  
  • Nature or type of interest held  
  • Extent or scope of interest held, expressed as a percentage of participation  
  • Starting date from which the final beneficiaries meet one or more requirements to be considered as such  

To consult the project, click here. 

Dominican Republic sets threshold to determine obligation to prepare transfer pricing study. 

The Dominican tax authority published a resolution that states taxpayers whose transactions with related parties during fiscal year 2023 do not exceed DOP 14,774,559 would not be obliged to prepare a transfer pricing study for this period, provided that they have not carried out transactions with tax havens or preferential tax regimes.   

 To consult the resolution, click here. 

Dominican Republic: portal for filing Country-by-Country Report is enabled  

Additionally, the tax authority of the Dominican Republic has enabled an electronic portal for the filing of Country-by-Country Reports by ultimate parent companies that are resident in the Dominican Republic, or by the member entity that has been designated in accordance with local legislation for its filing.   

The ultimate parent companies subject to the report are those with consolidated revenues equal to or higher than DOP 38.8 billion. The submission of the report for fiscal year 2022 will be available until May 31st, 2024.   

To learn about the portal, click here. 

United Kingdom: consultation on transfer pricing reform and other tax issues   

On January 16, the UK Government published a summary of the consultation’s responses to the proposed reform of regulations relating to transfer pricing, permanent establishment and diverted profits tax.   

Four public meetings were held in which more than 300 people participated and 43 written responses were received from companies, agents and representative bodies. 

We expect that the summary will provide additional clarifications on the transfer pricing rules, in some cases to bring them more in line with OECD guidelines. Concerns were raised about additional reporting obligations for permanent establishments that are not subject to income tax in the UK, and the intention to maintain the diverted profits tax was highlighted, as it is seen as a useful tool for the UK Treasury.   

The reform seeks to modernize UK domestic regulation, ensure that multinational entities are subject to the same level of taxation as other companies operating in the UK, develop simpler and more understandable legislation, and encourage inbound investment by improving tax certainty and access to treaty benefits.   

To read the publication, click here. 


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