TP International Advisors LLC
Today, February 26, 2025, is the final deadline for submitting public comments on Resolution MH-DGT-RES-000-2025, issued by the General Directorate of Taxation. This resolution provides an opportunity for entities representing general, corporate, or diffuse interests to submit their observations on the proposed guidelines for the submission of the Transfer Pricing Informative Return.
Law Nº 15,079, enacted on December 27, 2024, establishes the Additional Social Contribution on Net Profit (CSLL) as part of Brazil’s effort to align with the Global Anti-Base Erosion Rules (GloBE Rules) under the OECD’s Pillar II Inclusive Framework. This law aims to implement an effective minimum taxation of 15% for multinational groups generating annual revenues of at least 750 million euros, thereby ensuring greater equity and transparency in international taxation.
Following the launch of the new Virtual Office in May 2024, the old DET Live system will be replaced.
The Dominican Republic continues to take firm steps towards aligning its Transfer Pricing obligations with OECD standards.
This Resolution issued by the Internal Revenue Service (SII, from Spanish) in December 2024 places special emphasis on Transfer Pricing (TP) and is aligned with Tax Compliance Law N° 21.713 of September 25, 2024, which provides new tools to the SII to combat informality, evasion, avoidance, and organized crime.
The Brazilian Federal Revenue Service (Receita Federal, RFB) has issued Normative Instruction RFB No. 2,246/2024, which amends the previous regulations on Transfer Pricing (TP) in commodity transactions between Brazilian companies and related parties abroad. This new regulation, which comes into effect on January 1, 2025, aims to ensure that transfer prices align with market practices and the arm’s length principle.
The Country-by-Country Report (CbCR) will come into effect in Honduras for fiscal years ending on or after January 1, 2025.
On March 19, 2024, the Tax Administration Service (SAR, from Spanish) announced the guidelines for the submission of the Country-by-Country Report by multinational companies with tax residence in Honduras, whose consolidated revenues exceeds the threshold of 750 million euros, through Agreement SAR-653-2023.
Lately, the Superintendence of Tax Administration (SAT, from Spanish) has been focusing on transactions between local related companies.
On December 13, 2024, the Colombian Ministry of Finance and Public Credit published the Executive Order 1,496 of 2024, modifying the list of non-cooperative and low or no taxation jurisdictions in Colombia.