‘Transparency’ is the latest term of art that has emerged from the OECD’s Action Plan with respect to its base erosion and profit shifting (BEPS) initiatives. But the obvious question that has consciously been ignored in the public domain is: where are the matching transparencies regarding determination of tax risks and identification of substantive issues by tax authorities upon commencement and conduct of an audit?
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Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities
The report is solid and balanced as it correctly underscores the ambitious institutional redesign that Brazil has undertaken in adopting a dual VAT model, experts tell ITR
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