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April 03, 2013
The research has now started for the new edition of World Tax and the first edition of World Transfer Pricing, International Tax Review's directories of leading tax and transfer pricing firms around the world.
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February 11, 2013
In a recent decision, the Supreme Federal Court of Brazil, which has jurisdiction over constitutional issues, acknowledged the need to examine whether the Brazilian Federal Constitution was violated by decisions of the Superior Court of Justice regarding Decision No. 106 to rule that the applicable statute of limitations will be tolled for purposes of tax debts, and therefore the right of Brazil’s tax authorities to make tax assessments will be maintained, where a matter is not adjudicated because of delays by the Judiciary.
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February 06, 2013
In a recent decision, the Supreme Federal Court of Brazil, which has jurisdiction over constitutional issues, acknowledged the need to examine whether the Brazilian Federal Constitution was violated by decisions of the Superior Court of Justice regarding Decision No. 106 to rule that the applicable statute of limitations will be tolled for purposes of tax debts, and therefore the right of Brazil’s tax authorities to make tax assessments will be maintained, where a matter is not adjudicated because of delays by the Judiciary.
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September 01, 2010
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September 01, 2010
Augusto Martín Camarero and Armando Cabrera describe the way Argentine transfer pricing rules still fall behind more developed tax codes. The lack of advance pricing agreements and quasi acceptance of secret comparables cause problems.
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September 01, 2010
Simone Dias Musa, Clarissa Machado and Camilla Lagrasta explain how not following the OECD guidelines makes the Brazilian rules difficult to follow. With fixed margins regardless of industry and new thin capitalization rules, taxpayers need to be aware of the complex legislation.
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September 01, 2010
In Chile, the rules technically follow the OECD guidelines, but Miguel Zamora and Ana Paula Güitrón say it is not clear whether this is true. Advisers still struggle to know which transfer pricing methods are allowed.
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September 01, 2010
In Mexico, the transfer pricing rules have been in force since 1997, a relatively long time in Latin America. Moisés Curiel, Carlos Linares and Emilio Angeles talk taxpayers through staying on the right side of the notoriously strict
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September 01, 2010
Since the arm's-length principle was introduced in Peru in 2001, there have been multiple updates and extensions to the rules on transfer pricing. Claudia González-Béndiksen and Paola Gutiérrez list the important points taxpayers must be aware of, such as maintaining stringent documentation as well as filing an annual sworn informative return.
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September 01, 2010
Ronald Evans and Gustavo Sánchez discuss Venezuela's complex rules and explain that taxpayers must strive to comply with the legislation or face heavy penalties.
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September 01, 2010
Andrea Bazzo Lauletta and Luiz Felipe Centeno Ferraz of Mattos Filho, of Veiga Filho, Marrey Jr e Quiroga Advogados in Brazil explain how the country is modernising its categorisation of tax havens and privileged tax regimes.
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April 01, 2010
Getting off the blocks
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April 01, 2010
Tax saving opportunities carry considerable weight in the decision about the best M&A structure in Brazil, explain Cristiane Magalhães and Fabíola Costa Girão of Machado Associados