The qualification of technical services in Brazilian double tax treaties and the possible impacts of the adoption of article 12B, UN Model Convention Leonardo Thomaz Pignatari
By: Pignatari, Leonardo Thomaz
.
Material type: 
ArticlePublisher: 2021Subject(s): ECONOMÍA DIGITAL | SERVICIOS DIGITALES | ASISTENCIA TECNICA | DOBLE IMPOSICION | CONVENIOS | BRASIL
In:
Intertax v. 49, Issues 8-9, August/September 2021, p. 674-690Summary: The qualification of income derived from technical services in Brazilian double tax treaties has always been surrounded by significant controversy between tax authorities and taxpayers. The article examines the possible impacts of including Article 12B, the recent United Nations (UN) proposal for the taxation of the digital economy, in the qualification of technical services in Brazil. The article begins with the brief historical incursion into the qualification of technical services in Brazil and an overview of the new Article 12B of the UN Model Convention. In addition, it addresses the possible impacts of the adoption of such a provision in the Brazilian scenario and exposes the primary aspects of this new proposal. Finally, it discusses the Brazilian service taxation policy in the context of the digital economy.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 2141/2021/8/9-6 (Browse shelf) | Available | OP 2141/2021/8/9-6 |
Browsing IEF Shelves Close shelf browser
Disponible también en formato electrónico.
Resumen.
The qualification of income derived from technical services in Brazilian double tax treaties has always been surrounded by significant controversy between tax authorities and taxpayers. The article examines the possible impacts of including Article 12B, the recent United Nations (UN) proposal for the taxation of the digital economy, in the qualification of technical services in Brazil. The article begins with the brief historical incursion into the qualification of technical services in Brazil and an overview of the new Article 12B of the UN Model Convention. In addition, it addresses the possible impacts of the adoption of such a provision in the Brazilian scenario and exposes the primary aspects of this new proposal. Finally, it discusses the Brazilian service taxation policy in the context of the digital economy.
Click on an image to view it in the image viewer
There are no comments for this item.