Tax & Accounting Blog

MERCOSUR EFTA FTA

MERCOSUR EFTA FTA

Mercosur country members[1] and the European Free Trade Association (EFTA) bloc formed by four European countries – Switzerland, Norway, Iceland and Liechtenstein, have successfully completed the exploratory dialogue and preliminary negotiations for a free trade agreement. From the Brazilian government’s point of view, this new FTA clearly promotes a significant update of its … Read More

U.S. GAO Releases Report on BEPS Effects on U.S. Multinationals

U.S. GAO Releases Report on BEPS Effects on U.S. Multinationals

On January 27, 2017, the U.S. Government Accountability Office (GAO) published a draft report, Information on the Potential Impact on IRS and U.S. Multinationals of Revised International Guidance on Transfer Pricing (GAO-17-103), for the U.S. Internal Revenue Service (IRS) and Treasury, both of which have provided comments. In the report, the GAO analyzes … Read More

Chile Requires Taxpayers to Maintain Registry of Controlled Foreign Entities

Chile Requires Taxpayers to Maintain Registry of Controlled Foreign Entities

On January 20, 2017, the tax authority (Servicio de Impuestos Internos) published Resolution No. 9 (the “Resolution”), establishing the content and format of the registry that Chilean taxpayers, which directly or indirectly control entities located abroad (“controlled entities”), should maintain in accordance with article 41 G of the Income Tax Law … Read More

India Publishes Guidelines to Determine Company’s Place of Effective Management

India Publishes Guidelines to Determine Company’s Place of Effective Management

On January 24, 2017, India’s Ministry of Finance published Circular No. 6 of 2017, which provides guidelines for determining the place of effective management (“POEM”) of a company. See BEPS Action 6. Finance Act 2015 amended Section 6(3) of the Income Tax Act (“ITA”), effective from April … Read More