Aspectos Econômicos e Jurídicos do Investimento Direto Estrangeiro frente ao Direito Tributário Internacional

Abstract

Considering the multiplicity of the States involved in the productive process of businesses, which seek the highest profits at the lowest costs, it is possible to discover diverse taxation occurrences on the same income obtained by foreign direct investment. And this happens because the taxability of income tax can be realized, in total or in part, in the territory of more than one State, provoking the most varied tests of qualification and localization, besides those realized within the Brazilian State.