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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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