Cristiane M. S. Magalhães and Iara M. S. Sousa do Amaral of Machado Associados explains why a decision of the Federal Regional Court of Appeals of the 3rd region (TRF) may become an important precedent for transfer pricing in Brazil.
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Two months since EU political agreement on pillar two and few member states have made progress on new national laws, but the arrival of OECD technical guidance should quicken the pace. Ralph Cunningham reports.