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‘Good faith’ in tax treaties by Lucas de Lima Carvalho

By: Carvalho, Lucas de Lima.
Material type: ArticleArticlePublisher: 2024Subject(s): FISCALIDAD INTERNACIONAL | TRATADOS INTERNACIONALES | BUENA FE | ESTADOS UNIDOS In: Tax Notes International v. 114, n. 10, June 3 2024; p. 1495-1500Summary: Lucas de Lima Carvalho is an international tax lawyer specializing in Latin American taxation and emerging technologies. He is based in São Paulo. In this installment of Ahead of Tax, Carvalho explains the potentially problematic nature of the terms “bona fide” and “good faith” in tax treaties and the ways in which they can open the door to judicial interpretation that strays from the intentions of the contracting states.
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Lucas de Lima Carvalho is an international tax lawyer specializing in Latin American taxation and emerging technologies. He is based in São Paulo. In this installment of Ahead of Tax, Carvalho explains the potentially problematic nature of the terms “bona fide” and “good faith” in tax treaties and the ways in which they can open the door to judicial interpretation that strays from the intentions of the contracting states.

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