Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
The UK-based big four spin-off firm has hired Marc Lien, who declared that most AI in professional services today is ‘cosmetic’
Projected revenue losses and exemption requests are harming the project’s capability and viability
Sponsored
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Sponsored by DeloitteJess 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 -
Sponsored by DeloitteDeloitte pillar two experts Chad Hungerford and Alison Lobb share their insights on the latest developments and practical issues that are emerging – and what may lie ahead
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Sponsored by DeloitteDave Yaros, tax principal, Deloitte Tax LLP
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The Dutch government is standing by its plans to abolish century-old dividend taxes and cut corporate tax in a bid to remain attractive to multinationals like Unilever, Shell and Panasonic.
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Demand for advance pricing agreements (APAs) has increased despite in-house TP practitioners and their advisors saying that APAs don’t provide as much security as they used to and pose more risk.
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Alejandro Paredes of Deloitte provides an insight into the methods and characteristics of the Chilean tax authority’s transfer pricing (TP) team, and highlights how the training, expertise and professional outlook of the team has resulted in a focused, successful and understanding TP unit that is willing to liaise with taxpayers and tax advisors to achieve a positive outcome for all.
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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.
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The OECD BEPS project has quickly moved to the implementation phase, leaving an essentially changed landscape in its wake, write Deloitte practitioners from the Latin America Countries Organisation. This new environment requires businesses to reconsider their operational, financing and holding structures, identify communications strategies and assess their tax strategy, all with the aim of developing a maintainable tax framework.
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International Tax Review editor Joe Stanley-Smith introduces the 15th edition of the Latin America guide.
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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).
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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.
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Andrea Bazzo Lauletta, partner at Mattos Filho, looks at Brazil's recent adoption of regulations concerning ultimate beneficial owners of investments in the country.
