The Argentina Supreme Court of Justice has recently issued a significant decision that sheds light on a longstanding and highly debatable issue in the area of tax free reorganisations. Guillermo Teijeiro of Negri & Teijeiro Abogados analyses the conditions that need to be complied with when reorganisations take place within the same economic group.
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Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort