The Resource Dutch holding companies included in Brazilian grey list : controlled foreign company, thin capitalization and consolidation rules not applicable for 2015

Dutch holding companies included in Brazilian grey list : controlled foreign company, thin capitalization and consolidation rules not applicable for 2015

Label
Dutch holding companies included in Brazilian grey list : controlled foreign company, thin capitalization and consolidation rules not applicable for 2015
Title
Dutch holding companies included in Brazilian grey list : controlled foreign company, thin capitalization and consolidation rules not applicable for 2015
Creator
Subject
Language
eng
Summary
This article considers the material and temporal extent and effect of the changes to the Brazilian list of privileged tax regimes in relation to Dutch holding companies and, specifically, if these changes have implications for 2015 that affect filing in respect of the Escrituração Contábil Fiscal (Digital Accounting Register, ECF) in 2016
Citation source
In: Bulletin for international taxation. - Amsterdam. - Vol. 70 (2016), no. 11 ; p. 618-627
http://library.link/vocab/creatorName
Castro, L. Freitas de Moraes e
Language note
English
http://library.link/vocab/subjectName
  • holding company
  • grey list
  • transfer pricing
  • thin capitalization
  • case law
  • CFC
  • corporate income tax
  • retroactivity
Label
Dutch holding companies included in Brazilian grey list : controlled foreign company, thin capitalization and consolidation rules not applicable for 2015
Instantiates
Publication
Label
Dutch holding companies included in Brazilian grey list : controlled foreign company, thin capitalization and consolidation rules not applicable for 2015
Publication

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