‘Indeed,’ notes Francisco Castro Guedes of SRS Legal, ‘taxing today what was already decided and generated yesterday is always fertile ground for tax litigation’.
[...]
On this point, “it is essential to highlight what the OECD and the IMF have been stating: tax certainty and the stability of the rules are pillars of investment and growth; and temporary taxes on extraordinary profits, particularly when poorly calibrated, increase the risk perceived by investors”, points out Salomé Corte Real of SRS Legal.”