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Qualifying Investment Fund Income Under the Brazil-Spain Tax Treaty | Tax Notes International

Áreas Relacionadas:

Tax & Customs

Caio Malpighi, associate from Tax & Customs practice, is the author of an article published by Tax Notes International, which analyzes the characterization of income from the redemption and amortization of investment fund units under the Brazil-Spain tax treaty. The article discusses the approach adopted by Brazilian tax authorities and its treaty implications.

The analysis argues that such income should be characterized as business profits under the treaty, allocating taxing rights exclusively to the state of residence. The article also highlights tensions between the administrative interpretation and both domestic law and treaty principles.

Read the full article here.

Authors

Caio Malpighi

Associate

São Paulo

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