Search

Copyright of Revista Jurídica (0103-3506) is the property of Revista Juridica and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

During the last 15 years the Brazilian foreign direct investments have increased as a result of domestic and international economic favorable conditions. As of 2005 the Federal government has loosened rules for controlling and limiting currency exchanges, facilitating Brazilian foreign investments. Nevertheless, the Brazilian tax treatment of foreign income still does not stimulate outbound investments. In this article, we analyze the income taxation of individuals and legal entities resident in Brazil that invest abroad. Regarding the legal entities, we examine the Controlled Foreign Companies Rules (ìCFC Rulesî) and their compatibility with the Brazilian network of double taxation treaties, especially with the one in force between Brazil and Spain. [ABSTRACT FROM AUTHOR]