Abstract
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.
Talk to us
Join us for a 30 min session where you can share your feedback and ask us any queries you have
Disclaimer: All third-party content on this website/platform is and will remain the property of their respective owners and is provided on "as is" basis without any warranties, express or implied. Use of third-party content does not indicate any affiliation, sponsorship with or endorsement by them. Any references to third-party content is to identify the corresponding services and shall be considered fair use under The CopyrightLaw.