Taxpayers' Council rules again on compatibility of Brazil's CFC rules with tax treaties

The Brazilian Taxpayers' Council (Conselho de Contribuintes) considered once again the compatibility of the current Brazil's CFC rules with tax treaties. Differently from the previous decision of the 8th Chamber, the 1st Chamber of the Taxpayers' Council held that, irrespective of the treaty classification of the income earned by a Brazilian company through its foreign subsidiary, Brazil is prevented under the tax treaty with Spain to tax under its CFC rules the income of a for…