APPLICATION OF TREATIES TO AVOID DOUBLE TAXATION TO INVESTMENT FUNDS INCORPORATED IN BRAZIL

Authors

  • Guilherme Froner Cavalcante Braga

DOI:

https://doi.org/10.46801/2595-7155-rdtia-n6-7

Keywords:

LIMITATION ON BENEFITS CLAUSE, RESIDENT, PERSON, TRANSFER, AMORTIZATION, REDEMPTION, EXCLUSIVE FUNDS, INVESTMENT FUNDS, DOUBLE TAXATION TREATIES

Abstract

The present study analyzes the application of international treaties to avoid double taxation to investment funds established in Brazil, whose assets are located within the country, in relation to foreign investors, specifically with regard (i) to the access to treaty benefits by investment funds, (ii) to the qualification of gains and income deriving from investment funds and (iii) the limitation on benefits clauses.

Author Biography

Guilherme Froner Cavalcante Braga

Especialista em Direito Tributário pela PUC/SP, em Direito Tributário Internacional pelo IBDT e em Contabilidade, Controladoria e Finanças pela FIPECAFI. Advogado em São Paulo/SP.

Published

2022-02-16

How to Cite

Braga, G. F. C. . (2022). APPLICATION OF TREATIES TO AVOID DOUBLE TAXATION TO INVESTMENT FUNDS INCORPORATED IN BRAZIL. RDTI Atual, (6), 168–196. https://doi.org/10.46801/2595-7155-rdtia-n6-7

Issue

Section

Artigos