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The End of OECD’s Pillar I and Pillar II?

The recently issued memorandum for the Secretary of the Treasury addressing the OECD Global Tax Deal signals a major shift in U.S. tax policy, with significant geopolitical implications. Here’s a quick breakdown of the key aspects: -No Binding Effect Without Congress: Commitments

Chile Tax Compliance Bill

Last September, after passing through the Chamber of Deputies and the Senate, the so-called “Tax Obligations Compliance Project” (Bulletin 16621-05) was approved. Among the various points that the project includes/modifies within the framework of transfer pricing and mutational economic groups, we can

Unpacking Pillar One, Amount B from a Transfer Pricing Perspective

Ricardo Rosero, BaseFirma USA Background In late 2021, the OECD announced the preliminary design of its two-pillar approach to modernizing global taxation in the context of integrated, digitalized economies. Broadly speaking, Pillar One aimed to provide guidance on the proper allocation of

Brazil’s Transfer Pricing Overhaul: A Narrowing Window for Action

Introduction Despite the attention that has been directed to Provisional Measure No. 1152/22 (“the PM”) as it makes its way through Brazil’s legislative system toward becoming law (see BaseFirma’s original analysis of the PM here), it is difficult to overstate the practical

Brazil Publishes Provisional Measure Adopting OECD Transfer Pricing Guidelines

Key Points in this Article  Effective January 1, a “Provisional Measure” was published which significantly changes Brazil’s transfer pricing legislation by aligning it closely to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“the OECD Guidelines”).The Provisional Measure has

When the Price Isn’t Right

Transfer Pricing in the face of current macroeconomic conditions    Eduardo Emmerich, Senior Manager/Office Lead, BaseFirma Houston    Overview  In the last two years, multinational enterprises (“MNEs”) have faced a consistently turbulent and challenging macroeconomic environment at the local, regional, and global

Transfer Pricing for Start-Ups and International Expansions

Despite recent headwinds in global trade caused by supply chain bottlenecks and geopolitical conditions, multinational enterprises (MNEs) continue to grow in number, size, and economic importance. Companies in industries ranging from financial technology to biopharmaceuticals are seeking to profit from a more

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