Legal Profile for Luís Eduardo Schoueri – Lacaz Martins Halembeck Pereira Neto Gurevich & Schoueri Advogados from Who’s Who Legal. He obtained his doctors’ and free professor’s degree at the University of São Paulo, Brazil. He also has a master’s degree in law from the University of Munich, . Luis Eduardo Schoueri is the author of Direito Tributário ( avg rating, 0 ratings, 0 reviews, published ), Preços de Transferência no Direito Trib.

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The Brazilian legislation adopts the predetermined profit margins under the equivalents of the resale and… Continue reading. Registration Forgot your password? Edusrdo the formulation of tax policies with the underlying principles of taxation will ensure this objective is met. I — Article 12, when the protocol so provides II — Article 14, when the technical service is related to the technical qualification of an individual, except for cases included in I III — Article 7 in cases not covered in I or II.

If you wish to download it, please recommend it to your friends in eduarddo social system. In a ruling from June,the Revenue Service confirmed the long-standing Brazilian treaty practice of taxing income from services at source irrespective…. A fair example of this argument can be seen in Brazil. Furthermore, taxes should be uncomplicated in their design. Sovereignty and Development Investment Attraction.

Municipalities States Federal Union. We think you have liked this presentation. These economies have experienced significant growth, seeing an increase from less than 1. Technical services could be qualified under: A good taxation policy should ensure taxes are collected only after the relevant revenue earning activity has occurred, for example.

Share buttons are a little bit lower. This complexity in taxation policy has increasingly led to inefficiencies in trade, specifically in developing and emerging economies; it is costly for businesses and is an overall inhibitor to economic development.

In the fast-paced economic environment of the 21st century, many taxation regimes have strayed from the underlying principles of effective taxation policy. Globally, these changes have resulted in luos complex tax compliance requirements for businesses, a clear deviation from the underlying principles for the effective administration of a tax regime.


Now, more than ever, it is essential for governments across the globe to build policy around taxation foundations established to promote economic growth and stability. Given the Brazilian position on recent transfer pricing changes, these problems become… Continue reading.

Given the Brazilian position on recent transfer pricing changes, these problems become….

Luus use both our own and third-party cookies to enhance our services and to offer you the content that most suits your preferences by analysing your browsing habits. On a global scale, it is evident that there has been a schouueri increase in trade in the past decade, particularly in developing economies.

To use this website, you must agree to our Privacy Policyincluding cookie policy. You may change your settings and obtain more information by clicking on: It is imperative for tax authorities around the world to understand the overarching objective of a tax regime, which is to promote sustainable economic development.

According to these principles, the imposition of a tax should be structured to mitigate inconvenience to the taxpayer. My presentations Profile Feedback Log out. Japan and Turkey Example Brazil-Austria tax treaty: To make this website work, we log user data and share it with processors.

In such a case, the income may be taxed in that other State. The Department took heed of the opinion and enacted Declaratory ,uis No. My research has led to the writing of… Continue reading.

Prof. Dr. Luís Eduardo Schoueri – ppt video online download

Income derived by a resident of a Contracting State in respect of professional services or other independent activities of a similar nature shall be taxable only in that State, unless the payment schouri such activities and services is borne by a permanent establishment situated on the other Contracting State or a company resident therein. Two of the key underlying principles worth noting are convenience and simplicity.


These principles referred to as the canons of taxation, have been expanded upon since their advent. Your continued use of the site means that you accept these cookies. Michielse Technical Assistance Advisor.

OK Taxation Regime in Kenya. Real Profit – Expenses Currently, trade and business practices are evolving at a frenetic pace primarily due to advancements in technology.

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Tax revenue emerged as a key pillar in the economic development of countries and as a significant source of wealth for governments. Michielse – 1 EU Harmonization: Feedback Privacy Policy Feedback. There is current political goodwill towards a tax reform agenda that aims to eduaddo to the basic principles of taxation.

About project SlidePlayer Terms of Service. Tax Sparing Source Taxation Broader concept of PE Main challenges Eliminating distortions arising from domestic legislation Harmonizing tax collection and investment attraction Finding common interests to increase bargain in future negotiations. Brazil is known for its unique transfer pricing legislation. Article 12 royalties In Brazilian DTTs both countries would have right to tax; Article 7 business profits Only the country of residence should tax.

The argument for the importance of tax revenue in an economy has been well established since the 18 th century. Auth with social network: Incentive to grant the benefits of tax on imports Difficulty on taxing exports: BA should restitute amount collected by MG In the last few months I have been deeply committed with the Klaus Vogel Lecture, which will be held in September 25,in the Vienna University of Economics and Business see invitation here.

They should be easily comprehended by taxpayers in order to both protect taxpayers against unfair treatment by tax authorities and to discourage tax evasion.

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