June 2017  
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Bulletin for International Taxation
 
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Issue No. 6 - 2017 of the Bulletin for International Taxation is now available online.

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Number 6 - 2017 contains the following:
IFA CONGRESS ARTICLES

Brazil/International

President's Welcome

Porus F. Kaka

Dear Ladies and Gentlemen, Senhoras e Senhores and IFA Friends, bem-vindo ao 71st Congresso da IFA que se realizará de 27 de Agosto a 1 de Setembro de 2017. Welcome to the 71st IFA Congress, which is to take place in Rio from 27 August – 1 September 2017

Brazil

Brazilian Anti-Avoidance Legislation: Recent Refinements and Major Deviations from International Practice

João Francisco Bianco and Ramon Tomazela Santos

The authors, in this article, consider the main features of the Brazilian anti-avoidance legislation, thereby providing a general overview of the topic.

Brazil

Permanent Establishments and the Taxable Presence of Non-Residents in Brazil

André de Souza Carvalho and Juliana Andrade Costa

In this article, the authors consider the concept of a permanent establishment as set out in Brazilian and international tax law and its implications for the taxable presence of non-residents carrying on business activities in Brazil.

Brazil/OECD

Tax Transparency and Disclosure in Brazil

Edgar Santos Gomes

The author, in this article, considers the topics of transparency and disclosure with regard to taxation as these issues manifest themselves in relation to Brazil.

Brazil/OECD

The Brazilian Transfer Pricing Regime

André Gomes de Oliveira and Francisco Lisboa Moreira

In this article, the authors outline the Brazilian transfer pricing regime and consider its implications as well as the importance of recent developments, notably the OECD/G20 Base Erosion and Profit Shifting initiative.

Brazil/OECD/United Nations

Brazil’s Treaty Policy

Sergio André Rocha

The author, in this article, considers Brazil’s treaty policy as it has developed over time, with special reference to the influence of the OECD Model and the UN Model on this policy.

Brazil/International/OECD

Interpretative and Policy Challenges Following the OECD Multilateral Instrument (2016) from a Brazilian Perspective

Luís Eduardo Schoueri and Ricardo André Galendi Júnior

In this article, the authors consider the various interpretative and policy challenges that arise following the publication of the OECD Multilateral Instrument (2016), with emphasis on the Brazilian perspective.

Brazil/European Union/OECD

The Digital Economy and Indirect Taxation: The Brazilian Perspective

Diana Castro

This article examines the indirect tax challenges of the digital economy given the conclusions of the OECD/G20 Base Erosion and Profit Shifting initiative. In assessing the recent reforms regarding indirect taxation in Brazil, the article revisits the question of whether tax reform is needed in the digital sector.

Available online only

Brazil

The Judicial System of Brazil: Legal Remedies under the Brazilian Tax System

Bob Michel, Tatiana Falcao and Thais de Barros Meira

In this article, the authors provide an overview of the workings of the Brazilian judicial system, with special reference to the resolution of tax disputes.

Available online only

Brazil

Trends in Structuring Brazilian Mergers and Acquisitions: The Key Aspects of the Tax Amortization of Goodwill

Ricardo Seiti Ono and Doris Canen

Most mergers and acquisitions in Brazil are structured to enable the tax amortization of goodwill. This article examines how goodwill is treated in Brazil following the changes introduced by the adoption of international accounting standards and to the tax regulations, as well as considering the implications of recent court decisions.

Available online only

MAJOR FORUM FOR CROSS-BORDER DEVELOPMENTS AND INTERNATIONAL TAXATION