Three cases involving taxation on profits earned overseas were recently taken to a plenary session of the Brazilian Federal Supreme Court, but, despite taxpayers’ high expectations of a final position being delivered, the subject remains unsettled. Julio de Oliveira and Erika Tukiama, of Machado Associados, explain what the judgments did clarify and how the unanswered questions will be resolved.
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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