The BEPS project has seen the arm’s-length principle shift its focus to where human activity takes place, but Leonard ...
Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss a recent decision by the Brazilian Supreme Court that ...
Currently, in practice, by structuring a real estate company with multiple rental properties (leased to third parties) into ...
Teresa Teixeira Mota and Francisco Lencastre Torres of Vieira de Almeida & Associados explain how generative AI and enhanced ...
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente analyse a transfer pricing-related ...
Paolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici consider whether the regional tax on productive activities applicable to dividends distributed by subsidiaries to Italian parent c ...