On December 2 2010 the Brazilian government granted the exclusion of Spanish holding companies (ETVEs) from its grey list of privileged tax regimes. Isabel Bertoletti, Fabíola Costa Girão and Henrique de Freitas Munia e Erbolato of Machado report on the run-up to the removal.
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But businesses should remain flexible when choosing between internal and external resources to handle added ViDA complexity, ITR’s Indirect Tax forum also heard
The new managing director of R&D tax relief consultancy ForrestBrown tells ITR about his priorities for the business, where he’s focusing his time and what makes tax cool
A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented