Latin American regulatory regimes traditionally lack a general anti-avoidance provision permitting the tax authorities to
challenge transactions on the basis of their actual economic substance. But recent changes allow the tax authorities to seek out the substance over the form of a transaction. Prepared by the Latin American Business Centre of Ernst & Young in Europe
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Updated rules represent a significant shift in the Luxembourg TP landscape and emphasise the need for robust arm’s-length calculations, says Vanessa Ramos Ferrin of TransFair Pricing Solutions
Wopke Hoekstra also swore the EU would ‘hit back harder’ if faced with a trade war; in other news, a UK watchdog has launched an investigation into an audit completed by MHA
A recent UK First-tier Tribunal decision highlights the broad application of an anti-avoidance rule to deny tax relief, say Robert Waterson and Matthew Cummings of Eversheds Sutherland