The taxation of income earned by controlled and related foreign companies has become an increasingly important question as Brazil’s economy develops, since a growing number of Brazilian businesses now have investments in foreign companies that constitute a relationship of control explains Maurício Pereira Faro of Barbosa Müssich & Aragão.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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