Tax Videos

The meeting served as a joint call for the Mackrell International and MGI Worldwide Tax Practice Groups to share jurisdictional updates and experiences. Fernanda (MI) introduced herself as a partner at Velloza Advogados in Brazil and described a major tax reform concerning consumption taxes, including a dual VAT system with CBS and a supranational tax. She also noted that Brazil is implementing new transfer pricing rules based on OCDE standards and the Pillar Two key DMTT. Horacio (MGI) introduced himself as an economist in Monterrey, Mexico, with extensive experience in transfer pricing and valuation. He explained that Mexico is expecting a significant tax reform that would require companies exceeding a certain income threshold to maintain at least a 3% profit and would restrict loss carry forwards. He noted that Mexico has not yet implemented Pillar Two and that the relationship with the United States is currently strained. The two discussed the profit split method in transfer pricing, with Fernanda explaining its use in the Brazilian financial sector and Horacio explaining why it is rarely used in Mexico due to strict requirements for economic substance and the prohibition of pro rata approaches. Horacio recommended focusing on intangible asset strategies and DEMPE functions instead of profit splits. They also touched on the role of VAT in financial transactions and the challenges of proving the benefit of intra-group services to tax authorities.

The meeting commenced with co- chairs Fernanda Calazans (https://velloza.com.br/profissional/fernanda-junqueira-calazans/ , Brazil) and Joe Demko (https://sandbergphoenix.com/people/joseph-demko/ Missouri, USA) who focused on discussing Pillar 2 regulations and their implementation across different countries, with Fernanda providing an overview of Brazil's domestic minimum top tax and its alignment with OECD guidelines.

The discussion included perspectives from various tax professionals, including Joe and Soo Chye (Oaks Legal, Singapore), who shared insights on the U.S. and Singapore's tax regimes and their approaches to multinational corporations. The group explored the complexities of tax planning and corporate tax rates in different countries, concluding with plans for future meetings to focus on European perspectives and estate taxes.