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Showing 8361 - 8370 of 8916 for "Tax controversy" with applied filters

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.
News & Analysis

Luxembourg: New Bill of Law on simplification and modernization of certain procedural aspects in tax matters

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.
News & Analysis

Germany: Positive decision by the CJEU on the L-Case

11 April 2023 by KPMG - Luxembourg

Germany: Positive decision by the CJEU on the L-Case
News & Analysis

Parliament votes to reform Luxembourg arbitration law: what you need to know about the new law

23 March 2023 by Arendt & Medernach - Luxembourg

ON 23 MARCH 2023 THE LUXEMBOURG PARLIAMENT VOTED TO REFORM AND MODERNISE LUXEMBOURG ARBITRATION LAW THROUGH CHANGES TO THE NEW CODE OF CIVIL PROCEDURE. THE NEW LAW WILL TAKE EFFECT AFTER IT IS PUBLISHED IN THE MÉMORIAL (LUXEMBOURG OFFICIAL JOURNAL).
News & Analysis

ELTIF 2.0 – a new era of long-term investments is about to start

21 March 2023 by Arendt & Medernach - Luxembourg

WITH PUBLICATION OF THE REGULATION AMENDING THE ELTIF REGULATION, A NEW ERA OF LONG-TERM INVESTMENTS, ELTIF 2.0, IS ABOUT TO START. THE REVISED ELTIF REGIME WILL APPLY FROM 10 JANUARY 2024. HOWEVER, ELTIF MANAGERS MAY OPT INTO THE NEW REGIME FROM 9 APRIL 2023 UNDER CERTAIN CONDITIONS.
News & Analysis

Luxembourg: Recent legal developments in Real Estate

16 March 2023 by DSM Avocats à la Cour - Luxembourg

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.
News & Analysis

Tax & Revenue Law Update

15 March 2023 by Shearn Delamore & Co - Malaysia

Tax Case Update — JT Broadway Sdn Bhd (“taxpayer”) v Director General of Customs (“Customs”) and the Customs Appeal Tribunal (“Tribunal”)
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