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Individuals' Income under Double Taxation Conventions: A Brazilian Approach
Tax conventions (or tax treaties) provide a means of settling on a uniform basis the most common problems that arise in the field of international double taxation. Brazil has over two dozen such conventions in force. This number might seem small but the country will inevitably enter into more such treaties given its economic growth, foreign investments and economic globalization in general. Two highly practical aspects form the basis of the book’s analysis: interpretation and qualification under international tax law; and Brazil’s income tax on individuals. The author employs those starting points to tackle such thorny questions as: Is there coherence in the legal regime that is applicable to individuals’ income in double taxation treaties? Is this “system” for individuals consistent? Is it in accordance with Brazilian constitutional principles? Professionals dealing with Brazil’s tax regime will quickly find this work instructive, insightful and thought-provoking.
Individuals' Income Under Double Taxation Conventions
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.
Direito tributario internacional
Quem aufere renda em nosso país, como sabemos, está passível do pagamento de imposto de renda. E como fica a situação de quem aufere renda no exterior? Como é feita a tributação dessa renda? Como evitar a chamada 'dupla tributação'? Essas e outras questões são enfrentadas pelo autor neste trabalho que tem como pano de fundo as normas do direito internacional, em especial os tratados dos quais o Brasil é signatário.
Tributos e preços de transferência: Preços de transferência [...]
Analisa as políticas de preços de transferência e as práticas adotadas em conexão com a transferência de insumos, produtos, serviços ou intangíveis de uma afiliada para uma companhia relacionada localizada em outra jurisdição. Trata da importância do preço de transferência e seus impactos sobre a arrecadação tributária.
Environment Abstracts
This database encompasses all aspects of the impact of people and technology on the environment and the effectiveness of remedial policies and technologies, featuring more than 950 journals published in the U.S. and abroad. The database also covers conference papers and proceedings, special reports from international agencies, non-governmental organizations, universities, associations and private corporations. Other materials selectively indexed include significant monographs, government studies and newsletters.
Fibre & Fabric
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Introduction to the Law of Double Taxation Conventions
The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts ...
