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 Fiscal Year Ending on 03/31/23.
  • Paraguay: July 8 to 26.
  • Local Report and Informative Affidavit.

Americas: CIAT publishes section on Advance Transfer Pricing Agreements

The Inter-American Center of Tax Administrations (CIAT) published section 5.8. of the manual on the control of international tax planning, related to Advance Pricing Agreements (APAs). The section analyzes the APA concept, its characteristics, advantages and its proliferation in Latin America and the Caribbean. In addition, it provides mechanisms for negotiating and implementing APA programs.

To download and read the section, click here.


Colombia: tax treaty between Australia and Colombia under negotiation

On June 15, 2023, the Australian embassy announced via Twitter that Australia and Colombia are currently in negotiations for a tax treaty, the first of its kind between the two countries. Reports and updates will be provided as progress is made. It is important to remember that any resulting treaty will need to be finalized, signed, and ratified before becoming effective.

To view the announcement, click here.

Ecuador: update of rules for filing information regarding beneficial owners 

Through Resolution No. NAC-DGERCGC23-00000015, the Ecuadorean tax authority (SRI) amended the previous resolution that regulates the obligation to file beneficial ownership information. The new resolution establishes that the submission of the first annual report on beneficial owners must be submitted within the first three months following the date on which the SRI communicates that the process of implementation of the Registry of Beneficial Owners has been completed. 

In the same resolution, the definition of “legal structure” is modified, such that trusts and other legal entities organized or constituted abroad that have an administrator, fiduciary agent, protector or any other equivalent figure resident in Ecuador, are added as legal structures. 

To consult the resolution, click here.

Peru: indirect disposal of shares.

On May 23, 2023, the Peruvian tax authority (SUNAT), issued report No. 000064-2023-SUNAT/7T0000, which specifies the proper tax treatment of the indirect title transfer of shares in which one of the legal entities lists its shares on the stock exchange and the other does not. SUNAT concludes that, in the case of an indirect disposal of shares, the market value of the shares is determined by applying the highest listed value for the legal entity whose shares are listed on the stock exchange (or other mechanism), and by applying one of the methods provided in the Income Tax Law Regulations (discounted cash flow, equity value or appraisal value) for the other.

To consult the report, click here.

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