Expert Analysis

Multinationals are clambering over one another to try to establish themselves in Brazil, confident of the rich rewards such investment could reap while the country continues to harbour one of the world’s fastest growing economies. But how is Brazil’s tax administration coping with this changing business landscape? In an exclusive interview, Joe Dalton speaks with Monica Calijuri, Commissioner of the Federal Revenue of Brazil’s Large Business Office in São Paulo, to find out what part the tax authorities are playing in bringing more investment to Brazil.

To route their investments in a tax efficient manner, investors in the EU often use special purpose vehicles (SPV) incorporated in a third-party jurisdiction. The preferred jurisdictions are generally Luxembourg, the Netherlands, and, to a lesser extent, the UK or Switzerland (which benefits from certain EU directive rules under EU-Swiss agreements). Antoine Vergnat of McDermott Will & Emery in Paris provides a practical description of the main substance-related requirements that SPVs must satisfy to benefit from exemptions or reductions of withholding taxes on portfolio incomes derived from EU operating companies (which assets are not predominantly made up of real estate assets).

Steve Mendelsohn, managing director of Knowledge Solutions for the Tax & Accounting business of Thomson Reuters, looks at how the technology revolution is helping corporate tax professionals access better organised and more structured information for informed decision making.

Join Grant Thornton and insightsoftware on April 23 for a free ITR webinar exploring how flexible tax software aligns with your existing processes, enabling smoother adoption, integration, and phased implementation across complex organisations

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

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

Maria Gouveia of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines the most widespread misconceptions surrounding the regime, clarifying its tax deferral mechanism, effective rates, eligibility criteria, and scope

Rafael Calvo Salinero and Fernando Brioso de la Rica of Garrigues examine the implications of a Spanish Supreme Court ruling on treaty relief when the Interest and Royalties Directive exemption is denied

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the challenges and methodologies involved in determining arm’s-length prices for transactions involving intangible assets, addressing how to ensure compliance and mitigate tax risks