The increased diversification of the digitised economy presents a major challenge for BEPS initiatives. Lack of a permanent establishment (PE) had led to debate over where tax should be applied, even where a digital entity is not practising a tax avoidance strategy. The prospect of amended tax legislation to address this has raised concerns over the increased risk of double taxation, and a regulatory burden on multinationals.
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Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities
The report is solid and balanced as it correctly underscores the ambitious institutional redesign that Brazil has undertaken in adopting a dual VAT model, experts tell ITR
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