In-house tax professionals anticipate a Brazilian OECD membership will solve problems with complex transfer pricing rules and costly disputes with the tax authority. Calculating an arm’s-length price can be a challenge because Brazil’s most commonly-used transfer pricing method, the resale price method or PRL, has fixed margins.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns
After joining Milbank from Akin Gump, the fund tax specialist discusses sponsor demand, practice building, and the tax challenges facing asset managers
New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows
The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition