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 . . .
Davide Anghileri writes about the opinion of the Advocate General of the Court of Justice of the European Union in the Bevola case, delivered January 17, which concludes that a Danish law that precludes the deductibility of final losses incurred by a company’s foreign permanent establishment violates EU law . .
The Australian government on November 24 released a draft law and explanatory materials implementing hybrid mismatch rules to combat multinational firm tax avoidance. The Australian government is also developing a “targeted integrity rule” to prevent circumvention of the hybrid mismatch rules as well as branch mismatch rules to further clamp down on MNE tax . . .
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