Showing 761 - 770 of 829 for "FIUS - Finocchio & Ustra Sociedade de Advogados" with applied filters
28 June 2023 by
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.
15 June 2023 by
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.
19 May 2023 by
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.
11 May 2023 by
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
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
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
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).
13 April 2023 by
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.
16 March 2023 by
The Luxembourg legislator and administration have brought several legislative changes impacting the real estate industry in Luxembourg, and further legal initiatives have been announced in draft bills. The Luxembourg Constitutional Court also issued an important decision.
15 February 2023 by
The recent decision of the Court of Justice of the European Union (‘CJEU’) in case C-656/211, challenges the Stamp Tax liability applicable to marketing fees (and management fees including marketing services) paid by collective investment undertakings to management companies or financial entities (e.g., banks, credit institutions, etc.).