Showing 8351 - 8360 of 8911 for "Tax" with applied filters
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.
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").
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.
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).
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.
19 April 2023 by TPC Group - Peru
Although the Global Minimum Tax is not mandatory for all countries that signed the OECD and G20 Inclusive Framework declaration on BEPS, this tax would be in force as of 2024, for which Panama and other countries should review their current tax regulations and evaluate their tax incentives.
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.
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.
18 April 2023 by TPC Group - Peru
In recent years, Transfer Pricing control has become the main target of the international tax agenda promoted by the OECD worldwide. In this regard, TPC Group, a global specialized Transfer Pricing and Valuation firm, offers information from all the countries that have implemented Transfer Pricing regulations in its platforms.
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.
Register for FREE and enjoy the following benefits:
IFLR1000's Ranking Analysis allows you to:
Subscribe today, simply call +44 (0)20 7779 8154 or email rvalmarana@legalmediagroup.com
IFLR1000's Ranking Analysis allows you to:
Subscribe today, simply call +44 (0)20 7779 8154 or email rvalmarana@legalmediagroup.com