This content is from: Brazil

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

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.

To access our market-driven intelligence please request a trial here.

Read this article – and more – for a 30 day period.


Are you already an ITR subscriber? Log in here

Instant access to all of our content. Membership Options | 30 Day Trial