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Public input sought on Brazil, OECD transfer pricing harmonization
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 . . .
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Brazil proposal requires foreign digital platforms to collect new consumption tax
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 . . .
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The intercompany pricing of commodities: Alcoa versus the Australian Taxation Office
Dr. Harold McClure, an Economist based in New York City, discusses a transfer pricing dispute between the Australian Taxation Office and an Australian affiliate of US aluminum giant, Alcoa, which presents interesting questions regarding when comparable transactions should be considered uncontrolled transactions for transfer pricing purposes and how to select the best method for determining arm’s length prices for commodities such as alumina. . . .
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Intercompany interest deductions in the extractive sector
Economist Dr. Harold McClure of New York City discusses the taxation of intercompany financing in the extractive sector, focusing on likely tax disputes concerning the financing of Australia’s Gorgon natural gas project, the UN’s recent guidance on transfer pricing in the extractive sector, and the ConocoPhillips and Chevron intercompany financing litigations . . .
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Draft toolkit on the art of tax treaty negotiation offers tips for developing countries
Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, writes about a draft toolkit for tax administrations on tax treaty negotiation published on June 29 by the Platform for Collaboration on Tax, which is a joint initiative of the IMF, OECD, UN, and World Bank Group (WBG) . . .
