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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.
Transfer Pricing and Value Creation
Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax...
Tax Sovereignty in the BEPS Era
The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors pro...
How Fixed Is a Permanent Establishment?
Permanent establishment is the key concept for allocating taxation rights in respect of business income, and the question ‘Is there a permanent establishment?’ is a tax treaty issue that advisers, government officials, and courts perennially confront. Based on a ‘fixed link to the ground’, the idea has become progressively more difficult to apply until, at this stage, re-evaluation has become a political necessity. If a permanent establishment may exist in the context of e-commerce, the concept of a geographical presence must be redefined. However, the question remains: Is e-commerce a sufficient reason for challenging the well-established permanent establishment nexus? Drawing on ca...
Research Handbook on Corporate Taxation
Encapsulating the multitude of challenges faced by the international corporate tax regime, this timely Research Handbook provides an in-depth comparative legal analysis of corporate income tax as it is practiced across the world. With a variety of paths to reform proposed throughout, it will prove an invigorating read for tax scholars working on taxation and tax law as well as for tax practitioners and those in fiscal policy seeking ways to improve, or navigate, the current state of affairs in international corporate tax law.
Direito Tributário - 12a edição 2023
Uma nova proposta de estudo do Direito Tributário: é assim que o autor descreve este livro. O texto é apresentado em duas fontes tipográficas diferentes: uma delas oferece considerações mais gerais, ideal para um primeiro contato com a matéria; a outra indica estudos mais aprofundados e é, portanto, recomendada a pós-graduandos, profissionais e estudantes da graduação que desejam ir além do conhecimento elementar. O caráter didático do livro fica evidente já no índice sistemático, que cobre integralmente o conteúdo programático da parte geral do Direito Tributário. A dupla graduação do autor (bacharel em Direito pela USP e em Administração Pública pela FGV-SP) reflet...
International Cooperation in Tax Matters
This report contains guidelines for international tax practitioners dealing with the negotiation of double taxation treaties as well as those involved in the actual implementation of those treaties. The report deals with the issues from the point of view of taxpayers who would like to experience tax equity, non-discriminatory taxation, non-over assessment and non-double taxation.
