International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Expert Analysis

lead
Direct Tax
The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals
February 3, 2026
features sponsored features special focus local insights
  • The Brazilian presidential election in 2018 may substantially affect the transfer pricing (TP) analysis of local taxpayers and increase eventual adjustments on import transactions, as a consequence of an unfavourable exchange rate variation, writes Daniel Macedo of Deloitte.
  • Rodrigo Winter Salgado and Raul Fuentes Ugalde of PwC provide an update on imminent changes and the status of tax in the digital economy (DE).
  • Laws to deal with payments and the deductibility of royalties in Brazil were first introduced in 1958. For the past 50 years, relevant laws have been enacted with the goal of establishing clear rules and limitations. However, in some cases, as explained by Clarissa Giannetti Machado and Juliana Porchat de Assis of Trench Rossi Watanabe, these laws trigger conflicts of interpretation and relevant tax assessments.

Sponsored Features

Special Focus

Local Insights

Ad - shared