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Showing 2941 - 2950 of 3125 for "Americas" with applied filters

News & Analysis

Increase in Transfer Pricing Audits in Latin America

15 June 2023 by TPC Group - Peru

At the 7th International Tax Law Congress, organized by the Administrative Tax Court on Transfer Pricing, the perspectives thereon in Latin America were discussed, which highlighted the increase in the number of Transfer Pricing audits.
News & Analysis

Analysis Regarding the Transfer Pricing Harmonization Trend

05 June 2023 by TPC Group - Peru

Through an article published in the International Taxation blog Legal Today, Juliette Torres Ramos, a specialized lawyer in International Tax and Transfer Pricing, expressed the possibility of international harmonization and consensus on Transfer Pricing with a view to 2022.

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

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

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

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

The Profit Test as part of Intragroup Services

06 March 2023 by Carlos Vargas Alencastre - TPC Group - Peru

The Profit Test is a requirement incorporated into Peruvian regulations through Legislative Decree No. 1312, published on December 31, 2016, and effective from January 1, 2017, establishing that, as a necessary condition for the deduction of the cost or expense generated in related company transactions, certain criteria forming part of the so-called "Profit Test" must be complied with.
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