As widely reported, the signing ceremony of the Multilateral Convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting ("MLI") took place on 7 June 2017, in…
On 24 November 2016, the OECD released the Multilateral Convention designed for the implementation of tax treaty measures related to the Base Erosion and Profit Shifting (“BEPS”) Project. The…
Brazil is known for its unique transfer pricing legislation. While in most countries the use of comparables is central for the application of the transfer pricing methods, the Brazilian system has…
On September 14th, 2016, the Brazilian Federal Revenue Service (“RFB”) published the Normative Instruction RFB No. 1,658/2016, which included legal entities incorporated as holding companies in…
Introduction
While tax legislation is subject to continuous changes, tax treaties are an interesting tool whereby Contracting States offer investors some degree of legal certainty, especially where…
The world is following with attention the developments of one of the major all-time corruption scandals, involving one of the symbols of the Brazilian economy, Petrobras. If it was not enough fuzz,…
