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Temas de Tributação Internacional
Com a crescente participação do Brasil no cenário internacional, culminada com o pedido de entrada na Organização para a Cooperação e Desenvolvimento Econômico (OCDE) e a participação no Projeto de Base Erosion and Profit Shifting (BEPS), os temas sobre tributação internacional são cada vez mais relevantes e atuais, não só para estudiosos e profissionais do direito tributário, como também para todos os praticantes dos mais diversos ramos jurídicos.
The Spiritual Rococo
A groundbreaking approach to Rococo religious d?r and spirituality in Europe and South America, The Spiritual Rococo addresses three basic conundrums that impede our understanding of eighteenth-century aesthetics and culture. Why did the Rococo, ostensibly the least spiritual style in the pre-Modern canon, transform into one of the world?s most important modes for adorning sacred spaces? And why is Rococo still treated as a decadent nemesis of the Enlightenment when the two had fundamental characteristics in common? This book seeks to answer these questions by treating Rococo as a global phenomenon for the first time and by exploring its moral and spiritual dimensions through the lens of pop...
ITP@20, 1996-2016
None
Mulatto
Set in the provincial Brazilian state of Maranhao before the abolition of slavery and the establishment of the first republic, this scathing expose relates the story of Raimundo, a young Brazilian of liberal ideas. Mulatto is also a love story, set in motion by biology and sentiment.
Brazil National Report for the 8th IFA Latin America Regional Congress (Subject 01 - Transfer Pricing).
In the context of BEPS Action Plans 8, 9, 10 and 13, related to Transfer Pricing Policy and Documentation, we present an analysis on its interactions with the existing anti-avoidance and protection rules to prevent base erosion currently in force. Brazil is a country that has always presented measures to maintain its taxing level, such as the limitations on remittance and deductibility of royalties, the fixed margin transfer pricing methods, its worldwide taxation on a current basis (with an scope that goes far beyond an original CFC rule) and its thin-capitalization rules, to name a few. These set of rules result in a good protection of the source, even if its companies or individuals have ...
