Expert Analysis

Around 20 years ago the Brazilian Government, in order to deter tax evasion in the country, introduced rules aimed at avoiding the undue transfer of profits through transactions conducted between multinational companies and their parents or associates abroad, writes Carlos Ayub of Deloitte Brazil. Since then, all movements of goods, services, and rights between entities in the same group have been subject to transfer pricing rules.

The 2014 Tax Reform Act and the 2016 Tax Reform Amendment Act gave the Chilean tax regulator new tools to contact taxpayers, request information, initiate examination processes and potential tax audits, and even to declare the termination of activities for certain businesses, write Roberto Carlos Rivas and Josefina Casals of PwC Chile.

As a follow-on of the energy reform, this sector has seen a new-found interest from participants who seek to invest in publicly traded securities. Ricardo Rendón and Carlos Enrique Naime from Chévez, Ruiz, Zamarripa investigate.

Join ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court

Interview with Candy Ye Tang, tax and business advisory leader, Deloitte China

Interview with Adham Hafoudh, partner, Tax & Legal, Deloitte Czech Republic

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

The ruling clarifies that Spain cannot restrict VAT exemptions for general services directly necessary to independent groups’ exempt activities, says Fernando Matesanz of Spanish VAT Services

Gabriel Caldiron Rezende of Machado Associados comments on the latest developments related to the beginning of the Brazilian consumption tax reform test phase and considers the next steps

Nils Schmid and Isabelle Berking of KPMG Sweden analyse the possibilities for sovereign wealth funds to claim refunds of Swedish withholding tax following a recent proposal referred to the Council on Legislation