In 2017, Brazil sent a formal request to the Organisation for Economic Co-operation and Development (“OECD”) to become one of its members. It seems that this decision -- made by the economic team of…
For many years, I have been advocating a drastic change in the distribution approach for taxing rights in international taxation. The focus of my criticism has been Article 7 of the OECD and UN Model…
Introduction
As the General Reporter for the Subject 2 (The Future of Transfer Pricing) of the 2017 IFA Congress in Rio de Janeiro, I joined the plenary session on August 29 in a panel chaired by…
In 2015, people around the globe celebrated the 800th anniversary of the Magna Carta Libertatum, considered to be the first constitutional-like document that established restrictions on a sovereign’s…
