Strategizing Multinational Tax Risks

The Brazilian government has announced two new programs:

• Use of tax losses to offset currently disputed Federal tax liabilities
• Disclosure of tax planning structures that avoid, reduce or postpone taxes; such measures are meant to improve relationships between tax authorities and taxpayers.  This requirement is also meant to align with the OECD BEPS guidelines.  For planning structures implemented in 2014, disclosure is due by 30 Sept. 2015.  

Click to access 2015G_CM5636_Brazil%20uses%20tax%20losses%20to%20encourage%20cos%20to%20settle%20disputed%20tax%20liabilities.pdf

Additional disclosures and initiatives, aligned with BEPS guidelines, will be introduced in legislation by other countries, resulting in additional diligence requirements to avoid penalties.  Tax governance is becoming increasingly difficult and complex, underpinned by dissimilar compliance demands of each country.