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South America is in the throes of implementing the OECD BEPS project with new regulations emerging from every corner of the region, write Deloitte’s Latin America Countries Organisation practitioners. The developments clearly signal a tougher stance by authorities on transfer pricing and indicate that advance pricing agreements may be a key tool of the future.

The subject of transfer pricing (TP) has gained a great deal of momentum globally over the past couple of years. Most of the OECD and G20 countries have implemented TP legislation even before the BEPS initiative and have issued further regulations considering the recommendations of the BEPS Action Plan reports.

Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners analyse the new tax provisions concerning repatriated employees as well as brain gain tax advantages.

Ariane Costa Guimarães and Isabel Bueno of Mattos Filho provide an insight into the tax aspects of the social security reform in Brazil.

Dinesh Kanabar and Rishi Kapadia of Dhruva Advisors take a close look at India’s 2019-20 budget and the Finance Bill 2019, which together promise broad-reaching reforms to the tax regime.

Malta’s May 2019 tax amendment streamlines the treatment of corporate structures and offers a boon to intra-group transactions. Donald Vella and Kirsten Cassar of Camilleri Preziosi explain the changes.

Pedro Vidal Matos of Cuatrecasas reviews the EU Directive on Tax Dispute Resolution Mechanisms. Though far from perfect, it will enhance taxpayer protection and strengthen the EU’s double tax treaty network.

Kenny Mui of DLA Piper Australia analyses guidance published by the Australian Taxation Office on important Australian international tax measures that affect foreign investments in Australian structures and other cross-border transactions

Carolina Palma of EY evaluates developments in the trade and customs arenas in Central America, including several Central American countries signing the Free Trade Agreement with Korea and the implementation of the WTO’s Trade Facilitation Agreement in the region.