Nélio Weiss Philippe Jeffrey The tax treaty for the avoidance of double taxation and the prevention of fiscal evasion concluded between Brazil and Russia on November 22 2004 is expected to be effective as of January 1 2010. The treaty, which is mainly based on the OECD model, sets out standard regulations on permanent establishment and business profits issues and limits withholding tax rates on remittances. Yet, article 22 of the tax treaty, which grants taxing rights to the source country with respect to other income, still demonstrates a clear protection of exclusive source-based taxation rights, which is diverging from the OECD model convention.
June 30 2009