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Showing 8351 - 8360 of 8918 for "Tax%20controversy" with applied filters

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

Analysis Regarding the Transfer Pricing Harmonization Trend

05 June 2023 by TPC Group - Peru

Through an article published in the International Taxation blog Legal Today, Juliette Torres Ramos, a specialized lawyer in International Tax and Transfer Pricing, expressed the possibility of international harmonization and consensus on Transfer Pricing with a view to 2022.

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.
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

Walkers advises Allied Risk Group and its shareholders on sale of Allied Risk Management to Arthur J. Gallagher & Co

18 May 2023 by Walkers - Ireland

Walkers advises Allied Risk Group and its shareholders on sale of Allied Risk Management to Arthur J. Gallagher & Co
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

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.

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