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Showing 3391 - 3400 of 3654 for "General%20corporate%20tax" with applied filters

News & Analysis

LATAM Regional Profile (Tax Controversy)

16 July 2023 by Deloitte

LATAM Regional Profile (Tax Controversy)
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

We are pleased to announce our new Managing Partner, Maria Sagrado

19 May 2023 by Makarim & Taira S - Indonesia

Makarim & Taira S. (M&T) has entered a new chapter in its 43rd year as one of Indonesia’s leading law firms, with the appointment of Maria Sagrado as the new Managing Partner in May 2023.
News & Analysis

Transfer pricing: a strategic approach to pricing and revenue across countries

17 May 2023 by TPC Group - Peru

Currently, multinational companies face an increasing number of Transfer Pricing audits around the world, while tax authorities seek additional revenue and prioritize compliance and transparency.

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

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.

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