Brazilian Regime to Tax Controlled Companies Abroad Shall Not Be Considered CFC

Authors

  • Gabriel Bez-Batti IBDT

DOI:

https://doi.org/10.46801/2595-6280.58.8.2024.2650

Keywords:

TBU, CFC, STF, income tax

Abstract

In view of the analysis by the Brazilian Supreme Court of Extraordinary Appeal 870.214, which addresses, among other issues, the compatibility of Article 74 of Provisional Measure 2,158-35 with Article 7 of the tax treaties signed by Brazil, this article aims to highlight the reasons why Brazilian regime to tax controlled companies abroad shall not be considered CFC.

Published

2024-12-15

How to Cite

Bez-Batti, G. (2024). Brazilian Regime to Tax Controlled Companies Abroad Shall Not Be Considered CFC. Revista Direito Tributário Atual, (58), 186–206. https://doi.org/10.46801/2595-6280.58.8.2024.2650

Issue

Section

Doutrina Nacional (Double Peer Reviewed)