On 14 August 2014 the Philippines Court of Tax Appeals (“CTA”) decided case no. 1041 regarding Goodyear. However, the underlying issue was already decided in March 2013 by the same court in case no. 8188. I first discuss both cases before giving my impressions. Case No. 8188 The facts First, a summary of the timeline…

An issue of topical interest for tax administrations in the heat of the BEPS Plan, examining the existence of a PE does not seem to be on the agenda of Brazilian authorities. In a ruling from June, 2014, the Revenue Service confirmed the long-standing Brazilian treaty practice of taxing income from services at source irrespective…