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Showing 621 - 630 of 788 for "Mannrich e Vasconcelos Advogados" with applied filters

News & Analysis

Portugal - Beneficial owner: what’s in a name?

01 August 2023 by PLMJ - Portugal : João Guia Lopes and Afonso Massapina, associates in the Tax practice

The Portuguese Arbitration Court has recently issued the first decision on the application of the concept of beneficial owner in the context of the Interest & Royalties Directive (“IRD”).
News & Analysis

Deloitte Canada Regional Profile (Indirect Tax)

17 July 2023 by Deloitte

Deloitte Canada’s Global Indirect Tax (“GIT”) and Global Trade Advisory (“GTA”) practitioners provide indirect tax and global trade compliance, advisory, recovery, and technology enablement services to companies seeking to manage and optimize their indirect tax and global trade positions.

News & Analysis

LATAM Regional Profile (Tax Controversy)

16 July 2023 by Deloitte

LATAM Regional Profile (Tax Controversy)
News & Analysis

VAT reporting obligations in the Digital Age: any risk for personal data processing?

13 July 2023 by Baker McKenzie - Luxembourg : Florence D’Ath – Senior Associate, IPTech; Antonio Merino – Senior Tax Associate, VAT

On 3 March 2023, the European Data Protection Supervisor (hereafter, the “EDPS”) responded to the EU Commission’s consultation dated 10 January 2023 on the legislative proposal on VAT reporting obligations, assessing the potential impact on the right to personal data protection, within the package “VAT in the Digital Age”.
News & Analysis

Luxembourg: Clarifications on reverse hybrid entities

28 June 2023 by Baker McKenzie - Luxembourg: Diogo Duarte De Oliveira, Amar Hamouche and Antonio Weffer

On 9 June 2023, the Luxembourg tax authorities issued a long awaited circular1 ("Circular") on reverse hybrid provisions as set forth under Article 168quater of the Luxembourg Income Tax Law (LITL). The purpose of the Circular is to provide guidance on determining the net income and tax due by taxpayers falling under the scope of Article 168quater LITL, i.e., being reverse hybrids.
News & Analysis

Old vs new: does the wording of the GAAR really matter?

28 June 2023 by PLMJ - Portugal : Dinis Tracana and Rita Medalho

The Portuguese Arbitration Court (‘CAAD’) has recently ruled in three similar cases dealing with the application of the General Anti-Avoidance Rule (‘GAAR’).

News & Analysis

Luxembourg: Transfer pricing documentation requirements and new advance pricing procedures - highlights of the main changes

15 June 2023 by Baker McKenzie - Luxembourg: Diogo Duarte de Oliveira, Amar Hamouche and Antonio Weffer

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. Amongst others, the bill 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.

News & Analysis

Evolution of TP case law in Luxembourg — from zero to 100 in record time

08 June 2023 by Baker McKenzie - Luxembourg: Antonio Weffer, Elodie Schmidt

In the past few years, the Luxembourg tax authorities (LTA) have shown a growing interest in the examination of transfer pricing (TP) aspects of transactions carried out by multinational groups.
News & Analysis

Portugal changes its approach to debt-equity bias following the presentation of the DEBRA proposal

25 May 2023 by PLMJ - Portugal : Teresa Oliveira Braga, João Guia Lopes

In the wake of the European Commission’s proposal for a Directive aimed at tackling the debt-equity bias in the European Union (“EU”) (“DEBRA”), Portugal has changed its approach to this issue in order to align it with the Commission’s position.
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.
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