Americas
Brazil
Americas
Brazil’s effort to align its transfer pricing rules with OECD standards
Francisco Lisboa Moreira of Bocater, Camargo, Costa e Silva, Rodrigues Advogados, discusses the status of a joint effort of the OECD and Brazil’s tax authority to reduce the gaps between Brazil’s transfer pricing regime and the OECD transfer pricing guidelines ahead of Brazil’s ascension to the OECD . . .
Africa
Americas
Americas
Agreement reached on OECD transfer pricing guidelines for financial transactions, official says
Countries working on new OECD transfer pricing guidelines for financial transactions have reached agreement on virtually all issues associated with the project, The OECD’s Thomas Balco said June 4 at the 2019 OECD International Tax Conference. Balco also provided an update on other OECD transfer pricing projects, including the 2020 review of the country-by-country . . .
Americas
Americas
Brazil seeking to align transfer pricing regime with OECD norms
Francisco Lisboa Moreira of Bichara Advogados, São Paulo, discusses a joint project undertaken by Brazilian and OECD tax officials to more closely align Brazil’s international tax and transfer pricing regime with OECD guidelines, noting this project could result in changes to Brazil’s fixed margin and royalty deduction rules . . .
Americas
Americas
Brazilian tax authority rules cross-border payment for software as a service (SaaS) subject to withholding
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) . . .
Africa
Americas
Americas
Brazil’s country-by-country reporting obligation
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 . . .
Africa
Africa
Africa
BRICS country tax officials express support for “inclusive framework” on BEPS
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 . . .
Americas
Africa
Americas
Jamaica, Uruguay sign international tax cooperation agreement, Brazil deposits instruments of ratification
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 . . .
Americas
Americas
Brazil signs global tax agreement for automatic exchange of financial information
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 . . .
Africa
Americas
Brazil, Guernsey, Jersey, Isle of Man, Latvia sign agreement for exchange of tax reports on multinationals
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 . . .
Africa
Switzerland consults on introducing automatic exchange of tax information with 22 countries
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 . . .
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Africa
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Brazil
UN tax committee to consider major updates to transfer pricing manual, model tax treaty
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 . . .
Africa
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Brazil clarifies transfer pricing rules, approves protocol to tax treaty with Denmark
Francisco Lisboa Moreira, a partner with Bocater, Carmargo, Costa e Silva, Rodrigues, São Paulo, provides an update of recent Brazilian tax developments of interest to MNEs, discussing new Brazilian transfer pricing guidance and the Brazilian Congress’s approval of protocol to the Brazil-Denmark tax treaty . . .
