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) . . .
Dentons today announced that Cristiano Bortolotti will join the firm as a transfer pricing partner in the firm's Luxembourg office. Bortolotti will also develop and assist more broadly the tax practice . . .
Additional guidance on the implementation of country-by-country reporting by large multinational groups was released today by a countries known as the "Inclusive Framework on BEPS," the OECD has announced. This guidance is designed for both . . .
Monte Jackel follows up on his earlier article on the US Tax Court's decision in Grecian Magnesite discussing the collateral effects the ruling could have on the international tax rules for partnerships . . .
Mumbai attorney and transfer pricing specialist, Ajit Jain, discusses the OECD’s new transfer pricing approach to business restructuring, as described in Chapter IX of 2017 OECD transfer pricing guidelines, released July 10 . . .
The governments of Switzerland and Singapore today signed an agreement providing for the automatic exchange of information between tax authorities. Under the agreement, Switzerland will automatically exchange with the Singapore financial . . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses the implications of the US Tax Court's July 13 decision in Grecian Magnesite Mining, Industrial & Shipping Co. SA v. Commissioner, where the Court rejected the IRS’s aggregate approach for taxing a foreign partner’s gain on the redemption of its US partnership interest and concluded that the foreign investor was not subject to US taxation . . .
The UK government today announced it will reintroduce its finance bill, including legislation aimed at restricting the amount of interest and other financing amounts that a company may deduct for corporation tax purposes, “as soon as possible” after summer recess, after the . . .
Governments must work together on a regional basis to fight the harmful effects of tax competition and address multinational tax avoidance through devices such indirect transfers of assets, IMF Deputy Managing Director Mitsuhiro Furusawa said . . .