🌎 APET – Cursos Tributários has recently published a new issue of their prestigious journal Revista de Direito Contábil Fiscal da APET. This issue features 12 articles on themes ranging from transfer pricing documentation to foreign tax credits in CFC rules. The journal is coordinated by the President of APET, Marcelo Magalhaes

🌎 Revista Debates Tesis is a new publication of the Master’s Program of Budgetary and Tax Law of Universidad de Buenos Aires. Its goal is to give visibility to the theses defended by students of the Program. This inaugural issue is centered on the thesis of Anabella Kleiman, titled “Reglamentos

Introduction On November 19, 2025, the OECD published a much-anticipated update to its Model Tax Convention. This update includes many relevant amendments. Some have to do with Article 9 (a clarification of its scope vis-à-vis domestic laws – BEPS-inspired or otherwise – on interest deductibility), others with Article 25 (on