Brazilian attorneys, Francisco Lisboa Moreira and Carolina Silveira Becman of Castro, Barros, Sobral, Gomes, discuuss a Brazilian Federal Revenue Service's opinion on the taxation of amounts paid, credited, used, delivered, or remitted abroad on the acquisition of access and remote use of software as a service (SaaS) . . .
Francisco Lisboa Moreira, an attorney with Castro, Barros, Sobral, Gomes, discusses Brazil's country-by-country reporting requirement for large multinationals, identifying unresolved questions associated with the new rules . . .
Heads of revenue of the BRICS countries - Brazil, Russia, India, China, and South Africa - at a meeting held December 5--6 in Mumbai, expressed support for measures . . .
The Swiss government has today announced a consultation on commencing automatic exchange of information in tax matters with 22 countries, writes Davide Anghileri, a lecturer at the University of Lausanne . . .
Davide Anghileri of the University of Lausanne discusses Switzerland's November 18 signing of joint declarations on the introduction of automatic exchange of information in tax matters with Brazil, Mexico, and Uruguay . . .
Brazil has signed a multilateral competent authority agreement that creates the framework for the automatic exchange of financial account information under the OECD/G-20 common reporting . . .
Brazil, Guernsey, Jersey, the Isle of Man, and Latvia have signed a multilateral agreement which sets out the parameters for the automatic exchange between tax administrations of country-by-country tax reports on . . .
BRICS leaders, following their summit held October 15--16, called for tax policies that promote inclusive growth and expressed support for the implementation of the OECD/G20 base erosion profit shifting . . .
The UN Committee of Experts on International Cooperation in Tax Matters (Committee) has released several reports in advance of its annual meeting, slated for October 11--14 in New York, revealing that significant changes to the UN transfer pricing manual and model tax convention are . . .
See: DLA Piper.
Jamaica and Uruguay, on June 1, signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 95th and 96th jurisdictions to join the . . .
The BRIC countries of Brazil, Russia, India, and China have agreed to strengthen cooperation in areas such as transfer pricing and automatic exchange of financial account information to jointly crack . . .
Tax officials from 11 developing nations described the most common practices MNEs use to shift profits out of their countries, obstacles that prevent their countries from stopping these practices, and their reactions to the OECD/G-20 base erosion profit shifting (BEPS) project, responding to a UN request for . . .
The Brazilian Federal Revenue Department on June 8 issued Normative Instruction 1568/15 modifying the calculation of transfer prices based on Brazilian commodities methods applicable to imports and exports, writes PwC in a tax alert. See, PwC.
The Swiss government on November 24 announced that double tax agreements signed by Switzerland and Cyprus, Iceland, Estonia, and Uzbekistan have entered into force. The goverment also announced that Switzerland signed . . .
The Brazilian Revenue Service, in Declaratory Interpretative Act 07 (ADI 07/2014) released August 15, has modified its position concerning the tax treatment of amounts paid by a Brazilian residents to foreign legal entities for the provision of infrastructure for data processing and storage with remote access, deeming such payments to be payments for the provision of services, writes EY in an August 20 tax alert. For a discussion of the new guidance, see EY.
The US Treasury Department has updated its FATCA website, reporting that Brazil has signed a Model 1 intergovernmental agreement (IGA) with the United States as of Sept. 23. Agreement