Three cases involving taxation on profits earned overseas were recently taken to a plenary session of the Brazilian Federal Supreme Court, but, despite taxpayers’ high expectations of a final position being delivered, the subject remains unsettled. Julio de Oliveira and Erika Tukiama, of Machado Associados, explain what the judgments did clarify and how the unanswered questions will be resolved.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Australia’s Department of Finance will also commission an independent review of KPMG’s governance, culture, ethics and integrity frameworks, it has revealed.
In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses
ITR's latest podcast considers how transformational the buyout could be in Ryan's quest for global advisory reach and analyses a recent boom in demand for private client advisory services
The Irish government has been told that it’s spending too much of its corporation tax receipts and should instead focus on running bigger surpluses; plus, the IRS is set to merge tax practitioner offices
Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies