Brazil–MNE Tax

Americas

Brazil announces new transfer pricing regime

April 14, 2022

Francisco Lisboa Moreira, Bocater, Camargo, Costa e Silva, Rodrigues Advogados, discusses the details of the April 12 Brazil-OECD joint announcement on the main characteristics of Brazil’s new transfer pricing system.

Americas

NFTC letter to US Treasury Secretary Yellen requesting delay in the applicability of the foreign tax credit regulations: National Foreign Trade Council→

March 7, 2022

Americas

A regulatory tax hike on US multinationals

February 28, 2022

Daniel Bunn, Tax Foundation, discusses why a meaningful tax hike for multinational companies has already been adopted while much of the policy focus has been on proposals embedded in the Build Back Better agenda, which still has not yet made its way through the US Congress.

Africa

OECD releases third batch of transfer pricing country profiles for 28 jurisdictions: OECD→

February 28, 2022

Africa

Swiss international tax update addresses OECD deal, treaties, MAP

January 12, 2022

Switzerland’s State Secretariat for International Financial Matters on January 10 issued a report on various ongoing tax projects, including the country’s take on the OECD deal, as well as the status of tax treaty negotiations, tax information exchange, mutual agreement procedure (MAP), and recent . . .

Americas

Brazilian tax ruling applies most favoured nation clause in tax treaty with Portugal

December 23, 2021

Jack Taylor, University of Minho, discusses the Brazilian tax authorities’ September 22 ruling applying the most favoured nation principle in a case under the Brazil-Portugal double tax agreement, determining that sales of shares or equity by . . .

Americas

Brazil-Singapore tax treaty enters into force

December 1, 2021

The tax treaty between Singapore and Brazil, signed in May 2018, entered into force on December 1 and will become effective in January 2022 . . .

Americas

Brazil, China, Russia MAP tax dispute resolutions could improve, peer reviews show

October 19, 2021

There are signs that the competent authorities of Brazil, Russia, and China have insufficient resources to keep up with their caseloads for resolving tax and transfer pricing disputes through mutual agreement procedure (MAP), according to peer review reports released October 18 by the OECD, while . . .

Africa

G-24 warns that global tax deal will fail without better terms for developing countries

September 21, 2021

An international tax agreement on new profit allocation rules and a minimum tax will “not be sustainable even in the medium run” unless the terms allow developing countries to see fair shares under both pillars of the deal, the G-24 contended in September 19 comments submitted . . .

Americas

Brazilian National Congress approves income tax reform preliminary text

September 14, 2021

Carolina Becman and Kassia Paulo, Gaia Silva Gaede Advogados, discuss the Brazilian National Congress’s September 2 approval of the preliminary text for income tax reform, making important changes from the original draft and including a reduction in the corporate income tax rate from . . .

Americas

US R&D tax incentives will be among least generous unless Congress acts, study finds

September 8, 2021

The US will drop to a rank of 32nd among a peer group of 34 large economies in terms of its tax support for research and development (R&D) if it allows the new requirement to amortize R&D expense to take effect as scheduled in 2022, according to a September 7 study from . . .

Americas

Brazil’s upcoming tax reform will impact inbound investors

August 10, 2021

Luis Felipe de Campos, Rolim, Viotti, Goulart, Cardoso Advogados, discusses the substitute tax reform bill that Brazil’s Ministry of Economy presented to Congress on June 25, including provisions affecting corporate tax rates, profit distributions, interest . . .

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Americas

Brazilian tax reform’s second phase includes corporate, investment proposals

July 20, 2021

Carolina Becman and Kassia Paulo, Gaia Silva Gaede Advogados, discuss the Brazilian government’s June 25 presentation of the second phase of its proposed tax reform, which aims to change the income tax legislation for individuals and legal entities, as well as establish . . .

Africa

Irish tax treaty commentators disagree on approach to new negotiations

June 23, 2021

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

Africa

G20 draft communique reportedly endorses global minimum tax

June 22, 2021

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

Americas

G7 reportedly close to deal on new rules for taxing multinationals

May 24, 2021

The G7 group of leading economies is getting close to an agreement to shake up the global rules on the taxation of multinational businesses . . .

Africa

UN updates transfer pricing manual for developing countries

April 28, 2021

The United Nations’ latest edition of its practical manual on transfer pricing for developing countries, released April 27, adds new content on financial transactions . . .

Americas

Brazil’s Supreme Court addresses software taxation

April 28, 2021

Francisco Moreira, Bocater, Camargo, Costa e Silva, Rodrigues Advogados and Rachel Mira Lagos, Bocater Advogados, discuss a important Brazilian Federal Supreme Court ruling on software taxation . . .

Americas

Brazil proposal would enhance tax incentives for technology R&D

April 22, 2021

Doris Canen, International Tax LLM, discusses a bill to extend the benefits of Brazil’s R&D tax incentive that is pending before the Commission for Economic Development, Industry, Commerce, and Service . . .

Americas

US threatens tariffs against six more nations over digital taxes, drops investigation into others

March 29, 2021

The US Trade Representative has recommended trade actions against Austria, India, Italy, Spain, Turkey, and the UK following its findings that digital services taxes adopted by these countries discriminate against US companies. . .

Austria

Trade groups sue over Maryland’s controversial tax on digital advertising

February 22, 2021

Four organizations have joined in a lawsuit challenging a new Maryland state law levying a tax on digital ad revenue – the latest twist in an ongoing dispute with international implications. The US Chamber of Commerce, the . . .

Americas

US says Austria, Spain, UK digital taxes discriminate, warns on EU tax, three others

January 15, 2021

Digital services taxes enacted in Austria, Spain, and the UK discriminate against US companies within the meaning of Section 301 of the US Trade Act of 1974, the Office of the US Trade Representative . . .

Americas

US says Italy, India, Turkey digital services taxes are discriminatory, suspends France tariff action

January 7, 2021

Digital services taxes enacted in India, Italy, and Turkey discriminate against the United States; however, for now, no trade actions will be taken, the Office of the US Trade Representative . . .

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Americas

Brazil’s Supreme Court takes up taxation of software downloads

December 3, 2020

Francisco Lisboa Moreira and Rachel Mira Lagos of Bocater Advogados, Brazil, discuss a long-running Brazilian Supreme Court proceeding, stayed on November 11, that is expected to soon clarify the taxation of software downloads . . .

Americas

OECD, Brazil tax officials provide update of transfer pricing alignment project

September 28, 2020

Francisco Lisboa Moreira a tax partner at Bocater Advogados, São Paulo, Brazil, discusses a recent conference where senior OECD and Brazil tax officials provided an update on efforts to align Brazil’s transfer pricing laws with global standards . . . .

Americas

Netherlands announces changes to tax treatment of Brazil interest on equity payments

September 7, 2020

Jian-Cheng Ku and Mehdi el Manouzi, DLA Piper Nederland N.V., Amsterdam, discuss August 27 Netherlands Ministry of Finance guidance describing the new Dutch policy with respect to the tax treatment of interest on equity payments under the Netherlands-Brazil tax treaty . . . .

Americas

New Brazil digital services tax law under discussion

August 26, 2020

Francisco Lisboa Moreira, a Tax Partner at Bocater Advogados, São Paulo, Brazil, and Doris Canen, an International Tax LLM at Kings College/UK, São Paulo, Brazil, write about a Brazil bill, submitted August 18, which proposes to tax large tech companies on gross income derived from digital services provided to Brazilian customers . . .

Americas

Brazil lower house speaker Rodrigo Maia will oppose financial transactions tax, digital tax: Reuters→

August 19, 2020

Americas

Public input sought on Brazil, OECD transfer pricing harmonization

August 7, 2020

Francisco Moreira, a Partner, Bocater Advogados, São Paulo, Brazil, discusses a July 30 request made by the OECD and Brazil’s tax authority, Receita Federal, for the public to contribute to research regarding harmonizing the Brazilian transfer pricing legislation with the OECD transfer pricing guidelines . . .

Americas

Brazil proposal requires foreign digital platforms to collect new consumption tax

July 30, 2020

Francisco Lisboa Moreira, a tax partner at Bocater Advogados, discusses a bill presented by the Brazilian government to Congress on July 21 that would modify the country’s indirect tax laws and make digital platforms responsible for the tax liabilities of non-resident sellers of physical and digital goods . . .

Americas

US to investigate digital services taxes in India, Brazil, Turkey, Indonesia, the European Union, five EU countries

June 2, 2020

The Office of the US Trade Representative (USTR) today announced that it has initiated an investigation into digital services taxes proposed or adopted in . . .

Americas

Brazil proposes new digital tax on revenue

May 6, 2020

Francisco Lisboa Moreira, a tax partner with Bocater Advogados, Brazil, discusses a proposal for a Brazilan digital tax introduced to the House of Representatives on May 4 . . .

Americas

McDonald’s Brazil subsidiary must withhold tax on cost-sharing payments, court rules

February 4, 2020

Francisco Lisboa Moreira, a tax partner at Bocater Advogados, São Paulo, discusses a problematic decision of the Brazilian Administrative Tax Court in a case brought by a McDonald’s subsidiary concerning income tax withholding on payments made under a cost-sharing agreement . . .

Americas

Officials discuss aligning Brazil’s transfer pricing laws with OECD standards

December 20, 2019

Francisco Lisboa Moreira, a tax partner, Bocater Advogados, São Paulo, discusses Wednesday’s public joint-meeting between OECD and Brazil’s tax authority which again addressed aligning Brazil’s transfer pricing regime of Brazil with OECD standards . . .

Americas

Brazilian court rules that Oracle subsidiary may deduct outbound royalty payments

December 16, 2019

Francisco Lisboa Moreira, a tax partner at Bocater Advogados, São Paulo, discusses the Oracle case, decided by Brazil’s highest administrative tax court on December 3 . . .

Americas

OECD releases reports assessing cross-border tax dispute resolution in seven countries

November 29, 2019

OECD, on November 28, released peer review reports assessing cross-border tax . . .

Africa

BRICS countries look forward to further progress on two-pillar approach to address digitalization: BRICS Information Centre→

November 18, 2019

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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