IN THIS ISSUE
Latin American Transfer Pricing Developments
Strategies surveys transfer pricing issues concerning audits in Latin America during 2009. Page 1
Brazil Announces Tough Measures on Deductions
Brazilian tax officials in December announced a series of new measures in a year-end offensive to crack down on tax cheaters. Starting in 2010, individual taxpayers will pay a 75 percent fine for claiming deductions to which they are not entitled. They will also have to pay the full amount of any rejected deduction. Page 1
Brazil Enacts Thin Capitalization Rules
Thin capitalization rules have been introduced in the Brazilian tax system. These rules will impact many foreign companies with direct investment in Brazil, as it limits the deductibility (for income tax purposes) of cross-border interest payments at the level of the Brazilian affiliated legal entity. Page 6
Tax Litigation Opportunities and Pitfalls in Latin America
Strategies provides an overview of the practice of tax litigation in Argentina, Brazil, Chile, Colombia, Mexico and Venezuela, including the pros and cons of tax litigation in each of these countries and relevant tax saving opportunities for companies operating in Latin America. Page 16
