Brazilian update: Tax treaty with Spain clarified

January 31 2005

The Brazilian tax authorities issued on December 23 2004 the Interpretation Declaratory Act (ADI 27, which is an official interpretation from the Brazilian tax authorities), setting forth their understanding in connection with payments of dividends, royalties and service fees made under the Brazil-Spain Convention for the Avoidance of Double Taxation (the Tax Treaty)

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Transfer Pricing

UK TP proposals could ‘double compliance costs’, tax firm warns

Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP

Tom Baker, July 16 2025

Direct Tax

Pillar two no longer has a future, German chancellor claims

The global minimum tax deal is not viable without US participation, Friedrich Merz has argued

Sam Sholli, July 16 2025

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

Future of pillar two uncertain after Section 899 withdrawal averts ‘catastrophe’

Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars

Ralph Cunningham, July 16 2025

Direct Tax

‘Pro bono is a must’: Amory Heine on giving back

DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations

July 15 2025

Direct Tax

‘Huge, complex’ pillar two system encroaches on sovereignty: EY tax leader

Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut

Sam Sholli, July 14 2025

Direct Tax

London- HM Revenue and Customs building on Whitehall, UK Governm

HMRC believes US companies underpaid £8.8bn in tax: accountancy group

The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year

Sam Sholli, July 14 2025

Indirect Tax

This week in tax: Donald Trump announces 50% tariff on Brazil

The US president also unveiled a new 50% levy on copper imports; in other news, a UK wealth tax proposal has been criticised by the Institute for Fiscal Studies

Sam Sholli, July 11 2025

Direct Tax

Exclusive: WTS Global CEO steps down

Wim Wuyts, who had been head of the specialist tax network since 2017, is moving on to a new role with WTS’s Belgian member firm

Tom Baker, July 10 2025

Transfer Pricing

When algorithms decide tax outcomes: embedding ethics in TP systems

MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process

Sahasranshu Dash , July 10 2025

Transfer Pricing

Experts question whether UK TP proposal is ‘absolutely necessary’

The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities

Sam Sholli, July 09 2025