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.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The case sits within a context of Brazil signalling that it is replacing informal discretion and ambiguity with structures that reward analytical rigour, one expert tells ITR
Jeff Soar lifts the lid on WTS UK’s ambitious recruitment plans, the firm's positioning against the big four, and why tax is the perfect profession for AI
Nearly two years after its publication, the Corporate Tax Roadmap is reshaping the UK’s TP framework through incremental reforms focused on scope, transparency and earlier HMRC intervention