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Brazilian Court Rules on Compatibility of Brazilian CFC Rules and Tax Treaties with the Netherlands and Argentina

|Treaty Development|Brazil-Netherlands-Argentina
Brazil-Netherlands-Argentina

On 21 October 2014, the Brazilian Federal Administrative Court ruled on the compatibility of Brazil's CFC rules with the country's tax treaties with the Netherlands and Argentina in regard to income tax and the social contribution on net profits (CSLL). The case involved a Brazilian resident company that did not pay income tax and CSLL on the profits of its affiliated companies in the Netherlan…

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