What next for Brazil’s CFC rules?

June 30 2013

Three cases involving taxation on profits earned overseas were recently taken to a plenary session of the Brazilian Federal Supreme Court, but, despite taxpayers’ high expectations of a final position being delivered, the subject remains unsettled. Julio de Oliveira and Erika Tukiama, of Machado Associados, explain what the judgments did clarify and how the unanswered questions will be resolved.

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

Direct Tax

HMRC issues new guidance for online tax adviser registration system

Advisers who do not register for the new regime in time could be prevented from interacting with HMRC, the tax authority said

Sam Sholli, February 17 2026

Direct Tax

Pillar two not hollowed out by side-by-side deal: US tax leader

Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR

Sam Sholli, February 16 2026

Direct Tax

Baker Tilly International appoints new global head of tax

Ian Halligan previously led Baker Tilly’s international tax services in the US

Sam Sholli, February 16 2026

Direct Tax

What Corporates Want 2025 840x473 article header (1).png

A taxing week: DEI was slipping down the US agenda with or without Trump

Exclusive ITR data emphasises that DEI does not affect in-house buying decisions – and it’s nothing to do with the US president

Tom Baker, February 13 2026

Direct Tax

Close-up of handshake of businesswoman and businessman

This week in tax: McDermott, BakerHostetler bolster US tax partner benches

The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom

Sam Sholli, February 13 2026

Direct Tax

Tax Justice Network slams ‘shameless’ ICC report amid UN negotiations

The ‘deeply flawed’ report is attempting to derail UN tax convention debates, the Tax Justice Network’s CEO said

Sam Sholli, February 12 2026

Transfer Pricing

Morgan Lewis lures Baker McKenzie’s Americas tax leader in Washington DC

Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010

Sam Sholli, February 12 2026

Transfer Pricing

‘Aspirational’ MAP manual should be ‘go-to’ for taxpayers: OECD expert

While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’

Sam Sholli, February 11 2026

Direct Tax

Tiger Global analysis part 2: GAAR, JAAR and treaty benefits

The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief

Sanjay Sanghvi, February 11 2026

Direct Tax

IRS expands Tax Pro Account digital tool

The expansion introduces ‘business-level digital capabilities’ for tax professionals, the US tax agency said

Sam Sholli, February 10 2026