Double taxation relief under the Brazil tax treaty uses tax credits, exemptions, and limited credit rules for cross-border income. Methods for the elimination of double taxation under the Brazil tax treaty require the residence State to allow a deduction for tax paid in the other Contracting State, subject to the credit limit attributable to the relevant income. Where income is exempt in one State under the Convention, that State may still take the exempt income into account when computing tax on the remaining income. The text also refers to earlier special rules for deemed tax paid on certain interest and royalties and exemptions for specified dividend and profit income.
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Provisions expressly mentioned in the judgment/order text.
Double taxation relief under the Brazil tax treaty uses tax credits, exemptions, and limited credit rules for cross-border income.
Methods for the elimination of double taxation under the Brazil tax treaty require the residence State to allow a deduction for tax paid in the other Contracting State, subject to the credit limit attributable to the relevant income. Where income is exempt in one State under the Convention, that State may still take the exempt income into account when computing tax on the remaining income. The text also refers to earlier special rules for deemed tax paid on certain interest and royalties and exemptions for specified dividend and profit income.
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