The Supreme Federal Court (STF) of Brazil resumed its judgment in the case set to decide the constitutionality of the country’s controlled foreign company (CFC) rules yesterday and confirmed an injunction meaning mining multinational Vale will not have to pay its R30.55 billion ($15.09 billion) tax assessment until the court has made further analysis.
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Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
While Brazil’s consumption tax overhaul led to a short-term spike in tax advisory demand, we are now in a period of ‘normalisation’ marked by decreased recruitment