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Showing 171 - 180 of 292 for "Suryani Suyanto & Associates " with applied filters

News & Analysis

New Brazilian TP System Approved

19 May 2023 by FIUS - Brazil: Bruno Santo, Pedro H. Buffolo Jr., Fernanda Sampaio, Alice Oliveira

On May 10, 2023, the Brazilian Senate approved Provisional Measure No. 1,152/2022, which amends the transfer pricing legislation in Brazil and introduces the OECD transfer pricing model.
News & Analysis

The recent governmental proposals on amendments to the procedure governing direct taxation litigation in the Grand Duchy of Luxembourg

10 May 2023 by DSM Avocats à la Cour - Luxembourg

On 28 March 2023, the Finance Ministry sent Bill No. 8186, the provisions of which are aimed at amending and modernizing certain procedural aspects of direct taxation dispute resolution (the "Bill").
News & Analysis

Interactions between transfer pricing and customs rules further to the Hamamatsu case: a potential turmoil in Luxembourg?

04 May 2023 by Baker McKenzie - Luxembourg - Antonio A. Weffer, Antonio Merino

More than five years ago, the Court of Justice of the European Union ("CJEU") ruled in the Hamamatsu Photonics Deutschland GmbH (“Hamamatsu”) case that, according to the former EU customs legislation , a taxpayer cannot make ex post adjustments to customs value based on an intercompany agreement for goods under an advance pricing agreement (“APA”) concluded with the tax authorities.

News & Analysis

Luxembourg government proposes amendments to tax procedures

24 April 2023 by Arendt & Medernach - Luxembourg

On 28 March 2023, the government submitted to Parliament Bill of law no. 8186 amending the General Tax Law and introducing new provisions about transfer pricing and accounting.

News & Analysis

BEPS 2.0 Pillar Two: The minimum level of taxation for largest MNE Groups – Main challenges in the treatment of domestic tax incentives

18 April 2023 by Isaque Ramos, Ana Raquel Magalhães - PLMJ - Portugal

The adoption of the EU Minimum Tax Directive (2022/2523) ensuring a global minimum level of taxation for MNE Groups and large-scale domestic groups in the EU (also known as BEPS 2.0 Pillar Two) has raised some practical questions regarding how EU Member States will apply the global minimum corporate tax in their domestic legislation from the beginning of 2024 under the GloBE Rules.
News & Analysis

Luxembourg: New Bill of Law on simplification and modernization of certain procedural aspects in tax matters

13 April 2023 by Baker McKenzie - Luxembourg

On 28 March 2023, the government presented Bill of Law 8186 ("Bill"), which provides a set of amendments to the General Tax Law (Abgabenordnung, AO) dated 22 May 1931 and introduces new procedural aspects applicable to taxpayers.[1] The Bill also introduces new bilateral and multilateral advance pricing agreement procedures, together with the possibility to issue, withdraw or amend a tax assessment further to a mutual agreement procedure (MAP) or an arbitration decision. Lastly, the Bill proposes a transfer pricing (TP) documentation requirement for transactions between associated enterprises, while further details regarding the scope, exact content and magnitude will be unveiled soon in a coming grand ducal decree.
News & Analysis

Deloitte - Africa Regional Women in Tax interview (i)

15 March 2023 by Gloria Boye-doku

Interview with Gloria Boye-Doku, Africa Tax & Legal Partner, Global Employer Services (Ghana), Deloitte Africa
News & Analysis

New bill on Transfer Pricing multilateral procedures, administrative procedure and tax reclaims

14 March 2023 by KPMG - Luxembourg

New bill on Transfer Pricing multilateral procedures, administrative procedure and tax reclaims
News & Analysis

Ireland | Chambers 2023 Global Practice Guide on Investment Funds

08 March 2023 by Walkers - Ireland

Ireland | Chambers 2023 Global Practice Guide on Investment Funds
News & Analysis

European Union publication of the new list of non-cooperative jurisdictions – tax implications in Luxembourg

02 March 2023 by DSM Avocats à la Cour - Luxembourg

The European Union (the "EU") list of non-cooperative jurisdictions for tax purposes was updated by the Council of the European Union which added the British Virgin Islands (the "BVI"), Costa Rica, the Marshall Islands and Russia on 14 February 2023 (the "EU Blacklist").
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