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Showing 381 - 390 of 652 for "Facchini Rossi Michelutti Studio Legale Tributario" with applied filters

News & Analysis

Cooperation in tax collection: the increasing use of precautionary measures as a way of achieving a surprise effect.

18 May 2023 by PLMJ - Portugal: Priscila Santos, Raquel Santos Ferreira

In an increasingly interconnected world, where businesses expand their operations worldwide and capital flows across borders, not only does the issue of international taxation arise, but also cooperation between tax administrations, and this cooperation is an objective to be achieved in a European and international context.

News & Analysis

Transfer pricing: a strategic approach to pricing and revenue across countries

17 May 2023 by TPC Group - Peru

Currently, multinational companies face an increasing number of Transfer Pricing audits around the world, while tax authorities seek additional revenue and prioritize compliance and transparency.

News & Analysis

Provisional Measure No 1.152/22 revokes the limits imposed to the deductibility of royalties in Brazil

11 May 2023 by Vieira da Rocha Machado Alves - Brazil

Paulo Victor Vieira da Rocha, Murilo Jakuk Ferreira Lopes and Marina da Silva Fernandes of VRMA Advogados discuss the effects of the Provisional Measure No 1.152/22 regarding the deductibility of royalties from the corporate income tax assessment basis.
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

Superior Court of Justice grants final decision on subsidy for investment

02 May 2023 by FIUS - Finocchio & Ustra Sociedade de Advogados - Brazil

On April 25th, 2023, the Brazilian Superior Court of Justice (STJ) reached a unanimous decision on Theme 1182, which concerned the exclusion of ICMS tax benefits from the calculation of the Corporate Income Tax (IRPJ) and Social Contribution on Net Profits (CSLL).
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

New Transfer Pricing Rules Guide in Brazil

19 April 2023 by TPC Group - Peru

On February 24, 2023, the Receita Federal (IRS) of Brazil published Normative Instruction No. 2,132, which establishes the regulation of the taxpayer’s election to apply the New Transfer Pricing Rules provided for in Provisional Measure No. 1,152, dated December 28, 2022, to controlled transactions in 2023.

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

Germany: Positive decision by the CJEU on the L-Case

11 April 2023 by KPMG - Luxembourg

Germany: Positive decision by the CJEU on the L-Case
News & Analysis

Parliament votes to reform Luxembourg arbitration law: what you need to know about the new law

23 March 2023 by Arendt & Medernach - Luxembourg

ON 23 MARCH 2023 THE LUXEMBOURG PARLIAMENT VOTED TO REFORM AND MODERNISE LUXEMBOURG ARBITRATION LAW THROUGH CHANGES TO THE NEW CODE OF CIVIL PROCEDURE. THE NEW LAW WILL TAKE EFFECT AFTER IT IS PUBLISHED IN THE MÉMORIAL (LUXEMBOURG OFFICIAL JOURNAL).
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