The Dance of the Lions




Analyses of International Tax Treaties


(3) Structure of the Brazilian Tax Treaties in force in Brazil


§108. Once explained the origin and base of the international taxation of the income, lets focus, now, the structures of the Tax Treaties closed by Brazil, that can be understand in three big spheres, with their respective sub-subject, there being among the different agreements a little variation on the nomenclature of the sub-subjects, without substantial transformation, or in other words, without transformation in the essence on what was intended to bring forth by the name given to the sub-subject:

§109. General Sphere

- Persons Covered

- Taxes Covered

- General Definitions

- Resident

- Permanent Establishment

§110. Specification Sphere of the Taxed Facts

- Income from Real Estate

- Business Profits

- Air and Maritime Transportation

- Related enterprises

- Dividends

- Interest

- Royalties

- Capital Gains

- Independent Occupation

- Income from Employment

- Remuneration by Administration/ Directors’ Fee

- Entertainment Professionals and Sports-persons

- Pensions, Annuities and Payments of the Social Security System

- Public Functions/ Government Services

- Professors and Researchers

- Students and Apprentices

- Other Earnings

§111. Final Sphere

- Methods against Double Taxation

- Non-discrimination

- Friendly Procedural

- Exchange of Information

- Members of Diplomatic Missions and of Consulates

- General Dispositions

- Implementation/Entry in force

- Extinction/Termination

- End Protocol

* the model adopted by Brazil is from the Model Tax Convention on Income and on Capital of OECD (Organisation for Economic Co-operation and Development), with little changes, being Brazil a country which already made an adhesion request to join to the organisation, but the request still under analyses and judgment.


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Rafael De Conti, Rafael Augusto De Conti, Brazilian Tax Lawyer, Lawyer in Brazil