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.
This book is the rst in-depth commentary on this new and evolving area of international tax law.
Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specifi¬c source taxation rules, focusing on possible tax system changes and offering reform proposals.
This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital".
This report examines the practices of Member countries with regards to tax sparing and explains why Member countries have become more reluctant to grant tax sparing in treaties.
This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital.
This guide provides a practical, basic introduction to the tax consequences of transferring executives and specialists from one country to another.
This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law.
The United Nations Model Double Taxation Convention between Developed and Developing Countries: 2017 Update is a publication geared towards the international community especially developing countries and countries with economies in ...
This handbook aims at providing an introduction to the law of double taxation conventions.
This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio.