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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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. In a ruling from June,the Revenue Service confirmed the long-standing Brazilian treaty practice of taxing income from services at source irrespective… Continue reading. Tax revenue emerged as a key pillar in the economic development of countries and as a significant source of wealth for governments.

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Direito Tributrio Em Portuguese do Brasil, Luis Eduardo Schoueri. (Paperback )

Technical services could be qualified under: My research has led to the writing of…. They should be easily comprehended by taxpayers in order to both protect taxpayers against unfair treatment by tax authorities and eduaddo discourage tax evasion. To make this website work, we log user data and share it with processors.

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. Two of the key underlying principles worth noting are convenience and simplicity.

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

Michielse – 1 EU Harmonization: Furthermore, taxes should be uncomplicated in their design. Article 12 royalties In Brazilian DTTs both countries would have right to tax; Article 7 business profits Only the country of residence should tax.

According to these principles, the imposition of a tax should be structured to mitigate inconvenience to the taxpayer. Feedback Privacy Policy Feedback. In such a case, the income may be taxed in that other State. If you wish to download it, please recommend it to your friends in any social system. In the fast-paced economic environment of the 21st century, many taxation regimes have strayed from the underlying principles of effective taxation policy.


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. A fair example of this argument can be seen in Brazil. Currently, trade and business practices are evolving at a frenetic pace primarily due to advancements in technology.

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. Municipalities States Federal Union. Given the Brazilian position on recent transfer pricing changes, these problems become…. Sovereignty and Development Investment Attraction. These principles referred to as the canons of taxation, have been expanded upon since their advent.

We think you have liked this presentation. The Department took heed of the opinion and enacted Declaratory Act No. Real Profit – Expenses 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 of such activities and services is borne by a permanent establishment situated on the other Contracting State or a company resident therein.

Share buttons are a little bit lower. These economies have experienced significant growth, seeing an increase from less than 1.


In a ruling from June,the Revenue Service confirmed the long-standing Brazilian treaty practice of taxing income from services at source irrespective…. About project SlidePlayer Terms of Service. Michielse Technical Assistance Advisor.

We 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. Aligning the formulation of schoueeri policies with the underlying principles of taxation will ensure this objective is met. A good taxation policy should ensure taxes are collected only after the relevant revenue earning activity has occurred, for example. You may change your settings and obtain more information by clicking on: Registration Forgot your password?


I — Eduado 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.

BA should restitute amount collected by MG Given the Brazilian position on recent transfer pricing changes, these problems become… Continue reading. Adam Smith in his masterpiece, The Wealth of Nationsoutlines four underlying principles for the effective administration of a tax regime. The Brazilian legislation adopts the predetermined profit margins under the equivalents of the resale and….

Japan and Turkey Example Brazil-Austria tax treaty: Brazil is known for its unique transfer pricing legislation. On a global scale, it is evident that there has been a steady increase in trade in the past decade, particularly in developing economies. There is current political goodwill towards a tax reform agenda that aims to return to the basic principles of taxation.

An issue of topical interest for lusi administrations in the heat of the BEPS Plan, examining the existence of a PE does not seem to be on the agenda of Brazilian authorities. Incentive to grant the benefits of tax on imports Difficulty on taxing exports: My research has led to the writing of… Continue reading. Globally, these changes eduardi resulted in more complex tax compliance requirements for businesses, a clear deviation from the underlying principles for the effective administration of a tax regime.

Auth with social network: Published by Kory Warner Modified over 3 years ago. OK Taxation Regime in Kenya. To use this website, you must agree to our Privacy Policyincluding cookie policy.