Search results

Narrow your search

Result types
Article type
Jurisdiction
Practice area
Industry sector

Showing 71 - 80 of 266 for "Kim & Chang" with applied filters

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

Portugal changes its approach to debt-equity bias following the presentation of the DEBRA proposal

25 May 2023 by PLMJ - Portugal : Teresa Oliveira Braga, João Guia Lopes

In the wake of the European Commission’s proposal for a Directive aimed at tackling the debt-equity bias in the European Union (“EU”) (“DEBRA”), Portugal has changed its approach to this issue in order to align it with the Commission’s position.
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

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

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.

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

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

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).
Load more