1. Introduction The tax principles of legality, tax equality, and contributory capacity establish limits for Tax Administrations (TAs) and taxpayers. The latter cannot be artificially subtracted from a taxable event provided for in the law, avoiding its realization, with an artificial structuring; But neither can new taxable events be created,…

Part 1 IDB experience in PAT-e implementation The PROFISCO program is helping several Brazilian states drive digital transformation related to tax litigation. São Paulo: pioneering the implementation of PAT-e The state of São Paulo was the first Brazilian tax administration to develop, still in 2009, the electronic tax Administrative Procedure…

The Czech writer Franz Kafka became famous for telling stories of ordinary citizens getting lost in the corridors of a suffocating and inefficient bureaucracy. Until today, in a way, this is the image that the ordinary citizen has of the public administration: rooms crowded with piles of paper accumulating dust…

In memoriam Juan Carlos “Bebe” Gómez Sabaini, teacher and friend The digitalization of the economy has led to important changes in business models and in the value-creation processes of companies. From the fiscal point of view, a series of challenges arise, since tax systems, designed for another era and circumstances,…

As a consequence of a (primary) transfer pricing adjustment, economic double taxation may occur. However, in the treaties for the avoidance of double taxation (DTT) there is the figure of the correlative adjustment, which consists of the transfer pricing adjustment that should be made in the tax base of the…

The suggestion to integrate taxation regimes for segments of taxpayers with different characteristics of economic activity, tax liability, and/or tax capacity in a single general regime and the complications that some professionals see in the tax benefits granted by the socio-economic policy (from the blog: “Bridges to an Optimal Tax…

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