10Sep 2008
Brazil’s Federal Revenue Department (FRD), in a recent private letter ruling (PLR), has clarified the tax treatment of cost-sharing arrangements between a Brazilian company and its foreign parent company for transfer pricing and tax purposes. For both income tax and...
09Sep 2008
In an unprecedented decision, Brazil’s Superior Court of Justice (STJ) has ruled that an exporter may deduct as costs the accumulated tax credits of state value added tax (ICMS) if, because of its exempt export activities, the company cannot recover or use the credits...