Stephanie Makin

April 2022 saw the Brazilian Federal Revenue Service and the OECD present a proposal for the new Brazilian TP system

Recently, the highest level of the Federal Administrative Tax Court (CSRF) changed its longstanding view on the overlapping of Article 7 of the Double Tax Treaty (DTT) and the Brazilian Controlled Foreign Corporation (CFC) rules, now favouring taxpayers. 

In 2021, the United Kingdom’s Financial Conduct Authority announced several changes to the benchmark settings currently published by the ICE Benchmark Administration