Expert Analysis

Complainant Case or Action Adviser to complainant Respondent Court Next scheduled activity Agilent Technologies Mexico Administrativ Appeal of 2003 Tax Audit of import declaration Baker McKenzie Guillermo Villaseñor and Roberto Cardona Tax Service Administration Legal Section of the Ministry of Treasury Aracruz Celulose Right to use IPI credit premium Bichara Barata Costa & Rocha Advogados Luiz Gustavo Bichara and Luciana Martins de Oliveira Brazilian National Treasury Brazil's Superior Tribunal of Justice Aracruz Celulose Case before administrative tribunal to maintain tax benefits Bichara Barata Costa & Rocha Advogados Luiz Gustavo Bichara and Luciana Martins de Oliveira Brazilian National Treasury Federal Tax Appeal Council Auto Americano s/a Distribuidor de Pecas Case about exclusion of VAT from taxable basis Brazilian Federal Government Federal Supreme Court of Brazil Judgment suspended due to filing of constitutionality statemante action Brascan Quimicos e Soldas Ltd. Contesting tax assessment and penalties imposed by tax authorities Bichara Barata Costa & Rocha Advogados Luiz Gustavo Bichara and Luciana Martins de Oliveira Brazilian National Treasury Federal Tax Secretariat Awaiting 1st level administrative decision Caiua Servicos de Electricidade Contesting constitutionality of collecting VAT on leasing transactions State of Sao Paulo Federal Supreme Court of Brazil Judgment suspended due to request of case records for examination Global Vessels Mexico Withholding on chartering Baker McKenzie Guillermo Villaseñor and Roberto Cardona Mexican Tax Authorities Federal Tax Court of Mexico City Grupo Jumex, SA de CV Case over whether holding company should add losses to consolidated tax profit Basham Ringe & Correa Luis Ortiz Hidalgo and Ramiro Hernandez Mexican Tax Administration Service Mexican Federal Tax and Administrative Tribunal Heerema Marine Contractors Mexico Administrative Appeal of 2006 tax assessment for deductions of a Mexican branch Baker McKenzie Guillermo Villaseñor and Roberto Cardona Tax Audit Administration Federal Tax Court of Mexico City Inlogs Logistica Ltda, Incasa SA, A Guerra SA Implementos Rodoviarios Proceeding on applicability of tax immunity to export revenues Brazilian Federal Government Federal Supreme Court of Brazil Judgment suspended due to request of case records for examination Marcopolo S/A (acting as respondent) Administrative Proceedings Brazilian Federal Revenue Service Federal Administrative Council of Tax Appeals (Brazil) Taxpayer's appeal pending National Industry Confederation Proceeding challenging constitutionality of Brazilian CFC rules Brazilian Federal Government Federal Supreme Court of Brazil National Trade Confederation and National Industry Confederation Challenging constitutionality of the right of tax authorities to access taxpayer's bank information Brazilian Federal Government Federal Supreme Court of Brazil Nissan Mexicana, SA de CV Improper deductions for damages compensation Basham Ringe & Correa Luis Ortiz Hidalgo and Alejandro Arzate Mexican Tax Administration Service Mexican Supreme Court of Justice Judgment expected in spring 2011 Parati Petroleo Ltda Refund of difference in overpaid VAT State of Minas Gerais (Brazil) Federal Supreme Court of Brazil Judgment of the Full Session has been suspended Reckitt Benckiser Mexico Usufruct of Shares and Annulment Petition Baker McKenzie Guillermo Villaseñor and Roberto Cardona International Tax Audit Administration Federal Tax Court of Mexico City SC Johnson & Johnson, SA de CV Rejection of deduction for payment made by non-resident Basham Ringe & Correa Luis Ortiz Hidalgo and Alejandro Arzate Mexican Tax Administration Service First Circuit Collegiate Court on Administrative Matters Judgment expected in 2011 Sony DADC Mexico Tax Audit for the Fiscal Year 2002 (Recharacterisation of Dividends Baker McKenzie Guillermo Villaseñor and Roberto Cardona Mexican Local Tax Administration Mexican Federal Tax Court Sony DADC Mexico Administrative Appeal of 2003 tax assessment for royalty payments Baker McKenzie Guillermo Villaseñor and Roberto Cardona International Tax Audit Administration Legal Section of the Ministry of Treasury WDC Mexico Litigation against 2003 assessment Baker McKenzie Guillermo Villaseñor and Roberto Cardona Tax Audit Administration Federal Tax Court of Mexico City

Jorge Otoya of Estudio Muniz highlights how a decade of growth has made Peru an attractive location for foreign investment. But as tax reforms are introduced, questions are being asked if the changes will slow the country’s development.

With Luxembourg introducing transfer pricing guidance back in January, Begga Sigurdardottir, Marc Rasch and Utpal Sen of PwC discuss the practical implications of the new rules and discover that all is not clear for multinational taxpayers.

India’s transfer pricing overhaul expands safe harbours at scale and accelerates advance pricing agreements alongside the statutory recodification of the Income-tax Act, report Uday Ved, Hetav Vasani, and Jainesh Nahar of KNAV

Join KPMG and insightsoftware on June 25 as ITR presents a free webinar on the evolving role of tax professionals and how technology is driving the transformation

Jess Williams, Jimmy Man, and Olivier Hody of Deloitte explain how tax can be elevated from a post-close support function to a value-realisation tool in M&A transactions through quick wins and longer-term actions

Several South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how geopolitical conflict and economic volatility are reshaping transfer pricing risk and enforcement, with a particular focus on Southeast Asia and Indonesia

Monika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk

India’s Finance Act, 2026 introduces a tax framework for foreign companies using local data centres but leaves several questions unresolved, say S Vasudevan, Prachi Bharadwaj, and Loveena Manaktala of Lakshmikumaran & Sridharan

Nicolle Barbetti of Pérez-Llorca explains how the Capitalisation of Companies Incentive has reshaped Portugal’s corporate financing landscape and highlights how binding rulings have clarified key issues in its application

Natalia Núñez and Antonia Valdés of PwC Chile analyse the new bill’s tax implications for a key sector, considering the provisions of the Mining Royalty Law