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Showing 561 - 570 of 664 for "Junqueira Ie Advogados" with applied filters

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

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

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

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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