The Brazilian Thin Capitalization Rules and Tax Treaties: A Critical Approach

Journal
Brazil
Bulletin for International Taxation 2015 (Volume 69), No. 11
In this article, the author examines thin capitalization rules in general and, in particular, those introduced by Brazil by way of Law 12,249/2010, and the relationship of these rules with the provisions of tax treaties, specifically, the equivalents of articles 9(1), and 24(4) and (5) of the OECD Model.