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Mexico
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Africa
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Switzerland consults on introducing automatic exchange of tax information with 22 countries
The Swiss government has today announced a consultation on commencing automatic exchange of information in tax matters with 22 countries, writes Davide Anghileri, a lecturer at the University of Lausanne . . .
Americas
Mexico: transfer pricing documentation and country-by-country reporting rules finalized
Yoshio Uehara, César De la Parra, and Ignacio Mosquera of Chevez, Ruiz, Zamarripa, analyze final rules, issued by the Mexican tax authorities April 3, that implement the transfer pricing documentation and country-by-country reporting scheme set out in Action 13 of the OECD/G20 base erosion and profit shifting (BEPS) plan agreements . . .
Africa
Transfer pricing comparables “toolkit” reflects realities of developing nations, UN official says
A new “toolkit” which considers how developing nations can address a lack of comparables in transfer pricing, released jointly by the UN, OECD, IMF, and World Bank Group last June, reaffirms that the arm’s length approach can work for all nations but is also an imperfect, “not scientifically pure,” document, a UN official said July 18. Michael Lennard . . .
Americas
Americas
Brazil
UN tax committee to consider major updates to transfer pricing manual, model tax treaty
The UN Committee of Experts on International Cooperation in Tax Matters (Committee) has released several reports in advance of its annual meeting, slated for October 11–14 in New York, revealing that significant changes to the UN transfer pricing manual and model tax convention are . . .
Americas
Americas
Australia
31 nations sign agreement on exchange of country-by-country transfer pricing reports
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .
Africa
Americas
US, Mexico agree to transfer pricing framework for maquiladoras
The US IRS today announced agreement with Mexico on a transfer pricing framework for US multinational enterprises that have maquiladora operations which, if applied in . . .
Americas
Mexico: transfer pricing adjustment rules adopted
Yoshio Uehara and Ignacio Mosquera of Chevez, Ruiz, Zamarripa y Cía., Mexico City, discuss new Mexican provisions allowing for transfer pricing adjustments as of January 1 . . .
Americas
Americas
Switzerland agrees to automatic exchange of information with Brazil, Mexico, Uruguay
Davide Anghileri of the University of Lausanne discusses Switzerland’s November 18 signing of joint declarations on the introduction of automatic exchange of information in tax matters with Brazil, Mexico, and Uruguay
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Americas
Mexico transfer pricing comparability adjustments, the search for consensus
Jesús Aldrin Rojas a partner at QCG Transfer Pricing Practice, Mexico City, provides a comprehensive overview of a recent conference sponsored by the Universidad Panamericana Campus Mixcoac where Mexican tax officials and transfer pricing practitioners discussed new Mexican transfer pricing guidance . . .
Americas
Americas
Americas
Hong Kong signs AEOI pacts with Belgium, Canada, Guernsey, Italy, Mexico and Netherlands
Hong Kong signed treaties with six countries on March 16 for the automatic exchange of financial account information (AEOI) in tax. . .
Africa
Ireland tax treaty update: agreements with Zambia, Germany, Luxembourg enter into force; pacts with Ethiopia, Pakistan ratified; new treaty with South Africa under negotiation
Ireland’s tax treaty with Zambia and protocols to tax treaties with Germany and Luxembourg have entered into force and effect, Irish Tax and Customs. . .
Africa
Developing nations detail their experiences with BEPS, react to OECD work
Tax officials from 11 developing nations described the most common practices MNEs use to shift profits out of their countries, obstacles that prevent their countries from stopping these practices, and their reactions to the OECD/G-20 base erosion profit shifting (BEPS) project, responding to a UN request for . . .
Americas
Edgar Klee joins Haynes and Boone’s Mexico City office
Tax lawyer Edgar Klee has joined Haynes and Boone’s Mexico City office as a partner, the firm announced March 2. Klee who is formerly with Turanzas, Bravo & Ambrosi, focuses on international corporate taxation. . .
Americas
Mexico issues regulations on deductibility of pro rata expense allocations made by nonresidents to Mexican entities
Mexico issued regulations on October 16 on the deductibility of pro rata expense allocations made by nonresidents to Mexican entities and individuals, including special rules on the deductibility of services incurred between related parties, writes EY in an October 17 alert. For discussion, see, EY.
Americas
Mexico withholds VAT refunds owed MNEs while corporate tax bills in dispute – Reuters
VAT refunds owed Procter & Gamble, Unilever, and Colgate totaling hundreds of millions of dollars were withheld by the Mexican government while the companies were under investigation for tax avoidance, writes Henry Romero of Reuters in a September 1 article. See: Reuters.
