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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Recent ATO guidance on how companies can demonstrate arm’s-length funding highlights how it is ‘one of the most transparent tax authorities in the world’, one adviser tells ITR
The proposed Block TP Assessment could provide taxpayers with long-term arm’s-length price certainty and reduce admin headaches, Sanjay Sanghvi of Khaitan & Co writes