Individuals' Income Under Double Taxation Conventions

Individuals' Income Under Double Taxation Conventions
Author: Daniel Vitor Bellan
Publisher: Kluwer Law International B.V.
Total Pages: 466
Release: 2010-01-01
Genre: Law
ISBN: 9041132783

This book analyses the treatment of income of individuals under Brazilian double taxation conventions. Each article of the Brazilian tax treaties is analysed in order to identify its characteristics, field of application, limits and criteria applied in the identification of taxpayers. The OECD Model Convention is also considered, since it is mirrored in Brazilian conventions. The analysis reveals the unconstitutional nature of Articles 17 and 19 of the Brazilian treaties as they contradict the constitutional principle of isonomy.

Tax Conventions with Brazil, Canada, and Trinidad and Tobago

Tax Conventions with Brazil, Canada, and Trinidad and Tobago
Author: United States. Congress. Senate. Committee on Foreign Relations
Publisher:
Total Pages: 124
Release: 1967
Genre: Double taxation
ISBN:

Newly revised and expanded, the third edition of the Chambers Dictionary of World History contains many entries, providing clear and authoritative coverage of the most significant people, ideas and events of world history.

Individuals' Income Under Double Taxation Conventions

Individuals' Income Under Double Taxation Conventions
Author:
Publisher:
Total Pages: 323
Release: 2008
Genre:
ISBN:

This study analyses the treatment of income of individuals under Brazilian double taxation conventions. Each article of the Brazilian tax treaties is analysed in order to identify its characteristics, field of application, limits and criteria applied in the identification of taxpayers. The OECD Model Convention is also considered, since it is mirrored in Brazilian conventions. The analysis reveals the unconstitutional nature of Articles 17 and 19 of the Brazilian treaties as they contradict the constitutional principle of isonomy.

A Brief Comparison Between Brazilian and American Tax Systems

A Brief Comparison Between Brazilian and American Tax Systems
Author: Alessandra Norat Mousinho
Publisher: Editora Dialética
Total Pages: 68
Release: 2021-03-16
Genre: Business & Economics
ISBN: 6559562166

Na sociedade atual, em que temos muitos brasileiros investindo, trabalhando e residindo nos Estados Unidos, faz-se necessário compreender melhor o sistema tributário no Brasil e nos Estados Unidos, suas diferenças e semelhanças, bem como analisar mais profundamente como se dá a tributação de renda, especificamente de dividendos e ganho de capital. Este livro tem o objetivo de explicar ao leitor como funciona a tributação nos dois países de uma forma geral, aprofundando o tema na tributação de dividendos e ganho de capital.

The Qualification of Technical Services in Brazilian Double Tax Treaties and the Possible Impacts of the Adoption of Article 12B, UN Model Convention

The Qualification of Technical Services in Brazilian Double Tax Treaties and the Possible Impacts of the Adoption of Article 12B, UN Model Convention
Author: L.T. Pignatari
Publisher:
Total Pages:
Release: 2021
Genre:
ISBN:

The qualification of income derived from technical services in Brazilian double tax treaties has always been surrounded by significant controversy between tax authorities and taxpayers. The article examines the possible impacts of including Article 12B, the recent United Nations (UN) proposal for the taxation of the digital economy, in the qualification of technical services in Brazil. The article begins with the brief historical incursion into the qualification of technical services in Brazil and an overview of the new Article 12B of the UN Model Convention. In addition, it addresses the possible impacts of the adoption of such a provision in the Brazilian scenario and exposes the primary aspects of this new proposal. Finally, it discusses the Brazilian service taxation policy in the context of the digital economy.

Brazil{u2019}s International Tax Policy

Brazil{u2019}s International Tax Policy
Author: Sergio André Rocha Gomes Silva
Publisher:
Total Pages: 345
Release: 2017
Genre:
ISBN: 9788551901755

The focus of this research is the analysis of Brazil{u2019}s international tax policy, understood as the group of justifications and goals of the Country in the drafting of its domestic tax legislation, levied on cross-{u00AD}border transactions, and in the negotiation of international tax treaties. This analysis was made considering five different building blocks: Brazil{u2019}s double tax conventions; the Country{u2019}s transfer pricing and CFC regulations; the exchange of tax-{u00AD}related information; and the OECD/G-{u00AD}20 BEPS Project.