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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.

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

VAT and charging electric vehicles

28 April 2023 by Arendt & Medernach - Luxembourg

The Court of Justice of the European Union (CJEU) recently decided that the charging of electric vehicles which includes the supply of electricity and various adjacent services must be seen as a single complex supply of goods (P. in W., Case C-282/22, 20 April 2023).
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

Globe Model of Pillar 2 and its Implementation in Panama

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.

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

BEPS 2.0 Pillar Two: The minimum level of taxation for largest MNE Groups – Main challenges in the treatment of domestic tax incentives

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.
News & Analysis

TPC Group Gathers Information on Transfer Pricing from more than 80 Countries

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.
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