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    OECD and Brazil share outcomes of project to align Brazil’s transfer pricing rules to OECD standard

    Brazil and the OECD have been working together for the past 15 months to see whether a closer alignment between the TP system of Brazil and the OECD guidelines is possible. A joint statement of the outcomes was made public on July 11, 2019. Work p...
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    Implementation renewed Dutch ruling practice

    As per 1 July 2019, a new Decree on international tax rulings [1] (including Advance Pricing Agreements and Advance Tax Rulings), entered into force. The Decree of 19 June 2019 replaces the previous Decrees of 3 June 2014. However, rulings signed ...
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    Proposed new policy Dutch ruling practice – What’s new?

    On 23 April 2019, the new proposed Decree on international tax rulings (including Advance Pricing Agreements and Advance Tax Rulings) was published by the Dutch Secretary of State for Finance. It is intended that the new Decree will be implemented...
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    £107 million Diverted Profit Tax charge to Diageo: Is it a tax?! Is it a penalty?! Or is it proof that HMRC has superpowers…

    On May 10, Diageo, a FTSE 100 alcoholic beverage company, reported that it will have to pay a Diverted Profit Tax charge of £107 million in relation to a period of just 15 months. This evidences the approach HMRC is taking in inquiries where it do...
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