Intertax
Volume 42, Issue 6/7 (2014) pp. 427 – 432

https://doi.org/10.54648/taxi2014041

Abstract

In this article the author presents the internal review by the Brazilian tax authorities of its position concerning the treatment of technical service income under tax treaties against the background of recent court decisions and the manifested intention of the Finnish government to denounce the Brazil-Finland tax treaty. It reveals that, although the Article 7 v. Article 21 battle may be close to an end, some elements in the internal review process suggest that taxpayers may face an old and thought-to-be-over battle again .

Extract

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