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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

Tax Changes for 2023 and Their Effects on Transfer Pricing Rules

28 June 2023 by TPC Group - Peru

The tax authorities' innovations to be implemented must be known, concerning Transfer Pricing in particular.

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

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

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

Potential refund of stamp duty on the sale or lease of residential property for social housing

01 June 2023 by Walkers - Ireland

Potential refund of stamp duty on the sale or lease of residential property for social housing
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

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.
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