“I’ll do it tonight.” Let us imagine Laura, a self-employed professional who has just received a notice about filing her tax return. She knows she has to do it and intends to comply. She also recognizes the importance of taxes in funding public services. She opens the message on her…

560 total views, 63 views today

From October 14 to 16, 2026, I had the honor of participating in the IV Congress of Tax and Customs Law, organized by the Special Secretariat of the Federal Revenue of Brazil (RFB), and of intervening in a panel on the implementation of the Multilateral Instrument under BEPS Action 15…

965 total views, 65 views today

Indonesia’s Toba Pulp Lestari investigation poses a question for tax authorities worldwide: when does an international tax dispute become a corruption case? Where corruption offenses encompass losses to public finances, a proposed transfer pricing adjustment can become the starting point for criminal enforcement. Authorities need a defensible boundary. Deliberate deception…

2,050 total views, 86 views today

One of the greatest challenges faced by tax authorities taxing activities involving cryptoassets is identifying the parties involved. The growth of the cryptoasset market has created a recurring challenge for TAs in identifying the various participants for tax purposes. The problem arises because public blockchain ledgers display alphanumeric addresses and…

1,675 total views, 64 views today

A Guide to Sabotaging Tax Negotiations—Using Only Translators. Welcome to a practical workshop on how semantics can quietly sabotage regional integration. Language does more than label reality; it influences what we notice and how we classify it. In international tax discussions, this creates a dangerous illusion of false harmony: everyone…

1,823 total views, 64 views today

The tax administration in Venezuela is experiencing a significant change this year, 2026, due to the directives promoted by the SENIAT superintendent, Román Maniglia. With the central objective of achieving tax modernization, a model called the MODA model (Modernization, Digitalization, and Automation) has been structured. This initiative has generated great…

2,356 total views, 68 views today

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