The Brazilian Thin Capitalization Rules and Tax Treaties: A Critical Approach
Journal
Country
Brazil
Published Date
Issue
Bulletin for International Taxation 2015 (Volume 69), No. 11
Document
In this article, the author examines thin capitalization rules in general and, in particular, those introduced by Brazil by way of Law 12,249/2010, and the relationship of these rules with the provisions of tax treaties, specifically, the equivalents of articles 9(1), and 24(4) and (5) of the OECD Model.