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Individuals' Income Under Double Taxation Conventions. A Brazilian Approach

Individuals' Income Under Double Taxation Conventions. A Brazilian Approach

Individuals' Income Under Double Taxation Conventions. A Brazilian Approach

Author: Daniel Bellan
Publisher: Kluwer Law International
ISBN: 9789041132789
Published In: September 2010
Format: Hardback , 464 pages
Jurisdiction: Brazil ? Disclaimer:
Countri(es) stated herein are used as reference only

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Description
Contents

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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.

About the Author

Preface

Acknowledgements

Introduction

Chapter 1 Propaedeutic Comments

Chapter 2 Brief Introduction to Brazilian Individuals' Income Tax

Chapter 3 Interpretation and Qualification in International Tax Law

Chapter 4 Independent Personal Services (Article 14)

Chapter 5 Income from Employment (Article 15)

Chapter 6 Directors' Fees (Article 16)

Chapter 7 Artistes and Sportsmen (Article 17)

Chapter 8 Pensions (Article 18)

Chapter 9 Government Service (Article 19)

Chapter 10 Students (Article 20)

Chapter 11 Members of Diplomatic Missions and Consular Posts (Article 28)

Chapter 12 The Main Question: Legality of the Regime Applicable to Individuals' Income under Double Taxation Treaties

Conclusions

Bibliography

Index

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