Treaty Shopping and Beneficial Ownership under Brazil’s Tax Treaties

Journal
André Rocha, S.
Brazil
Bulletin for International Taxation 2012 (Volume 66), No. 7
PriceUSD 45

In this article, the author considers the application of article 3(2) of the OECD Model to Brazil’s tax treaties in identifying whether or not the definition in article 26 of Law 12249/2010 is adequate for the purpose of applying the rules in respect of treaty shopping and beneficial ownership.