TITLE

A TRIBUTAÇÃO DE INVESTIMENTOS BRASILEIROS NO EXTERIOR

AUTHOR(S)
RUSCHMANN, CRISTIANO FREDERICO; POMMORSKY, EDUARDO FUSER
PUB. DATE
June 2010
SOURCE
Actualidad Juridica (1578-956X);2010, Issue 26, p97
SOURCE TYPE
Academic Journal
DOC. TYPE
Article
ABSTRACT
During the last 15 years the Brazilian foreign direct investments have increased as a result of domestic and international economic favorable conditions. As of 2005 the Federal government has loosened rules for controlling and limiting currency exchanges, facilitating Brazilian foreign investments. Nevertheless, the Brazilian tax treatment of foreign income still does not stimulate outbound investments. In this article, we analyze the income taxation of individuals and legal entities resident in Brazil that invest abroad. Regarding the legal entities, we examine the Controlled Foreign Companies Rules (ìCFC Rulesî) and their compatibility with the Brazilian network of double taxation treaties, especially with the one in force between Brazil and Spain.
ACCESSION #
57345763

 

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