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ENSafrica | South Africa | 3 May 2022

ENSafrica tax in brief - Issue 81 | 2022-05

The High Court of South Africa, Western Cape Division, Cape Town Ι Tunica Trading 59 (Proprietary) Limited v Commissioner, South African Revenue…
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DLA Piper | Global | 5 Apr 2022

OECD releases draft Model Rules on Scope of Amount A under Pillar 1

On 4 April 2022, the OECD issued draft Model Rules with respect to scope under Amount A of Pillar 1 for public comment. Amount A establishes a new…
Commentary
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Machado Associados | Brazil | 1 Apr 2022

Decree 10,977/22 reduces IOF-Exchange rates to reach 0% in 2029

Decree 10,997/22 recently established the reduction of the tax on financial exchange transactions exchange rates to 0% in 2029. Currently, a general rate of 0.38% applies, but the applicable rules provide for some exceptions. According to Decree 10,997/22, the reduction will be carried out gradually until it reaches all exchange transactions. This reduction is connected to Brazil's entry......
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YPOG Partnerschaft von Rechtsanwälten und Steuerberatern mbB Schnittker + Partner | Germany | 25 Mar 2022

Ministry of Finance publishes letters on application of Royalty Limitation Rule

Recently, the Ministry of Finance published two circular letters that contained guidance for the application of the Royalty Limitation Rule. The letters focus on guidance related to the so-called "nexus escape" and the distribution of the burden of proof between tax authorities and taxpayers. Due to the commitment by Germany and the other EU member states to abolish IP regimes that were......
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Greenwoods & Herbert Smith Freehills Pty Ltd | Australia | 22 Mar 2022

Weekly Tax Highlights to 18 March 2022

On 14 March 2022, the OECD released technical guidance on the Global Anti-Base Erosion Model Rules (Pillar Two) to assist countries in implementing…
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DLA Piper | USA | 17 Mar 2022

OECD releases commentary on the Pillar Two GloBE Rules - observations on selected topics

The OECD has published its long-awaited technical commentary, together with illustrative examples, explaining the application and practical…
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DLA Piper | European Union, Global | 17 Mar 2022

OECD releases commentary on the Pillar Two GloBE Rules - observations on selected topics

The OECD has published its long-awaited technical commentary, together with illustrative examples, explaining the application and practical…
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Lexology PRO | Global, Ukraine | 16 Mar 2022

Interpol launches financial crime and corruption initiative

Practitioners said the self-described apolitical organisation has entered the financial crime arena at a moment when many future investigations will likely be driven by geopolitical tensions.
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CMS Luxembourg | Luxembourg | 4 Mar 2022

Impact of new OECD transfer pricing guidelines in Luxembourg

Recently, the Organisation for Economic Co-operation and Development (OECD) released a new version of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The adoption of the new guidance on financial transactions is particularly relevant for companies operating in Luxembourg, especially for those involved in financing activities such as investment funds, or......
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Machado Associados | Brazil | 4 Mar 2022

Tax challenges in Brazil's accession to OECD

After decades of discussions about Brazil becoming a member of the Organisation for Economic Co-operation and Development (OECD), Brazil has finally been invited to start its accession process to the organisation. There is no doubt that tax issues and changes for the alignment with OECD guidelines will be a challenge to be overcome in the complex Brazilian tax system.
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