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Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases
From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal
The firm’s eye-catching UK launch is a major statement of intent, but it will face stern opposition in its quest to be the top global tax player
The postponement came after industry representatives flagged implementation issues with the registration regime; in other news, firms made key tax partner additions
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Sponsored by MachadoBrazil has affirmed that sales to the Amazonian free trade zone of Manaus must be equal to export transactions. Machado Associados' Ricardo Debatin da Silveira and Rogério Gaspari Coelho discuss the implications for exporters over the last five years. -
Sponsored by Mattos FilhoBrazil's tax authorities may now establish liability of third parties before court judgement. Mattos Filho's Ana Paula S. Lui Barreto and Leonardo Fernandes Rebello discuss the impact to third parties and their defence.
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Sponsored by MachadoBrazil’s Superior Court of Justice (STJ), which has the power to deliver final decisions regarding legality (constitutional matters are addressed by the Brazilian Supreme Court – STF), has reaffirmed that sales to the free trade zone of Manaus (FTZM) – which is in the state of Amazonas – must be equal to export transactions. Companies that have sold inputs or merchandise to the FTZM can therefore recover tax credits to foster exports, under the Special Regime for Reintegrating Tax Values for Exporting Companies (REINTEGRA).
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