The Resource Service income under Brazilian tax treaties : the possible end of the article 7 v. article 21 battle, but the start of a new old one?

Service income under Brazilian tax treaties : the possible end of the article 7 v. article 21 battle, but the start of a new old one?

Label
Service income under Brazilian tax treaties : the possible end of the article 7 v. article 21 battle, but the start of a new old one?
Title
Service income under Brazilian tax treaties : the possible end of the article 7 v. article 21 battle, but the start of a new old one?
Creator
Subject
Language
eng
Summary
In this article the author presents the internal review by the Brazilian tax authorities of its position concerning the treatment of technical service income under tax treaties against the background of recent court decisions and the manifested intention of the Finnish government to denounce the Brazil-Finland tax treaty. It reveals that, although the article 7 v. article 21 battle may be close to an end, some elements in the internal review process suggest that taxpayers may face an old and thought-to-be-over battle again
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 42 (2014),
http://library.link/vocab/creatorName
Ferreira, V. Arruda
Geographic coverage
  • Latin America
  • South America
Language note
English
http://library.link/vocab/subjectName
  • tax treaty
  • technical services
  • transfer of technology
  • income classification
  • other income
  • royalties
Label
Service income under Brazilian tax treaties : the possible end of the article 7 v. article 21 battle, but the start of a new old one?
Instantiates
Publication
Label
Service income under Brazilian tax treaties : the possible end of the article 7 v. article 21 battle, but the start of a new old one?
Publication

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