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Brazilian Superior Court strikes down CFC rules as incompatible with tax treaties

Matthew Gilleard
May 14, 2014
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The Brazilian Superior Court of Justice (STJ) has ruled that the country’s controlled foreign corporation (CFC) regime is not compatible with the business profits article (Article 7, OECD Model Convention) of some of the tax treaties in its network.

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Matthew Gilleard worked at ITR between 2010 and 2016
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