The purpose of this study is to discuss the interpretation of administrative and judicial Courts in Brazil regarding municipal Tax on Services (ISS) in transactions involving exportation of services, since some courts have been interpreting the concept of result – whose occurrence in Brazil is what defines the application of ISS on exported services – as the conclusion of the services. This article demonstrates that interpretation is contrary to the principle of taxation at the destination, by which the good or service is taxed where it is consumed. This principle is adopted in Brazil and in more than 150 countries that have some form of value-added taxation (VAT), which includes taxes on services, such as the United Kingdom. The logic of the principle is to increase the competitiveness of national goods and services and avoid double taxation both at the origin and destination.
Intertax