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Tag: OECD Guidelines

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On October 9, 2024, Brazil’s Administrative Council of Tax Appeals (CARF) issued a landmark ruling in Acórdão 2202-010.938, reinforcing the Federal Revenue Service’s (Receita Federal) transfer pricing methodology. The case, […]

The OECD Inclusive Framework on Base Erosion and Profit Shifting (BEPS) has released a set of updates to support the coordinated implementation of the global minimum tax under Pillar Two. […]

Spain has introduced Law 7/2024, implementing global minimum tax rules under the OECD’s Pillar Two framework. This new law aligns Spain with the EU’s Council Directive 2022/2523 and reflects its […]

The Italian Supreme Court's latest ruling on OECD Guidelines provides crucial insights on method selection for transfer pricing in intra-group transactions.
This article examines the Italian Supreme Court's landmark ruling that mandates the inclusion of loss-making entities in transfer pricing comparability analyses, emphasizing the importance of aligning with OECD guidelines and adopting a more comprehensive approach
Brazil's shift to an arm's length standard for transfer pricing, aligned with the 2022 OECD Guidelines, marks a significant change for multinational enterprises. This new regime demands thorough documentation and strategic compliance to navigate its

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