ITR Search | International Tax Review

Certainty offered by APAs waning, but they remain popular

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.

Joseph Stanley-Smith, September 27 2018

The deductibility of royalties paid abroad: The new environment in Brazil

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.

September 26 2018

TP takes precedence across Latin America

International Tax Review editor Joe Stanley-Smith introduces the 15th edition of the Latin America guide.

Joe Stanley-Smith, September 26 2018

Brazilian real devaluation will influence 2018 transfer pricing adjustments

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.

September 26 2018

Taxes on the digital economy in Chile

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).

September 26 2018

The future tax potential in LATAM’s uncertain political and economic setting

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.

September 26 2018

In praise of the Chilean tax authority

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.

September 26 2018

Transparency and disclosure for investing in Brazil: The learning process of a trend

Andrea Bazzo Lauletta, partner at Mattos Filho, looks at Brazil's recent adoption of regulations concerning ultimate beneficial owners of investments in the country.

September 26 2018

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