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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).

A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to taxrelief@euromoneyplc.com

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.

There are two important taxes in Brazil used to finance the country's social security system: the Contribution Over Income (COFINS) and the Contribution to the Social Integration Program (PIS). These taxes must be paid by all legal entities and are imposed on their revenues resulting from the sale of goods, the provision of services, or both, explains Glaucia Lauletta, of Mattos Filho Veiga Filho Marrey Jr e Quiroga.

In recent years the Hungarian Tax Authority (HTA) has been concentrating more and more on transfer pricing issues and has publicly formulated views in relation to comparable searches. Zoltán Lipták and Hedvig Sólyomvári of Ernst & Young provide an overview of the most important aspects of these views and raise some questions in relation to their practical implications in light of the latest advance pricing agreement (APA) and tax controversy experience gathered by tax advisers.

Tom Seymour, PwC On August 13 2012, a 71 page Discussion Paper was released by a Government-appointed working group to canvass ways in which a cut to the company tax rate could be funded from within the business tax system.

John Leopardi and Emmanuel Sala, Blake Cassels & Graydon For decades, non-Canadian resident inter vivos trusts were not taxed in Québec on property income derived from Québec situated immovable property. Such trusts were only subject to federal tax at a maximum rate of 42.92%. Further to the Québec 2012-2013 Budget, Québec announced that non-Canadian resident inter vivos trusts (Specified Trust) will be liable to an additional 5.3% Québec income tax on income derived from the rental of immovable property situated in Québec (Specified Immovable Property), for a combined Canadian and Québec rate of 48.22%. Such inter vivos trusts will also be required to file a Québec tax return and compute rental income from the Specified Immovable Property separately from any other sources so that any losses from such other sources may not reduce the income earned in Québec from the Specified Immovable Property or vice-versa.

Rossitza Koleva, Eurofast Global Amendments to the Law on Excise Duties & Tax Warehouses, and to the VAT Law for the recording and reporting of sales in points of sale with fiscal devices entered into force on July 17 2012.

Chizuko Tomita, Morrison & Foerster The absence of specific Japanese rules on the treatment of a foreign subsidiary's reorganisation has sometimes hindered Japanese companies when trying to conduct reorganisations of their foreign subsidiaries for valid business purposes. Often, Japanese companies have had to approach the Japan National Tax Agency (NTA) in advance to obtain certainty on their tax treatment.