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

Journal
Monteiro, A.L. Moraes do Rêgo
Brazil
Bulletin for International Taxation 2015 (Volume 69), No. 11
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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.