The Dance of the Lions




Analyses of International Tax Treaties


(4.1) Double Taxation Treaty (DTT) Brazil-Belgium


(4.1.b) Covered Taxes


§117. In principle, the covered taxes on International Tax Treaties shall to have equivalence, in the meaning that the double taxation only occurs when different tax collectors entities taxing one and the same fact; Therefore, the taxes that are related to this fact, being of one or another jurisdiction, all have, necessarily, similarity (considering that they taxing the income). In the case of Belgium, there is the imposts on natural persons, societies, legal entities, non residents and the complementary contribution of crises, while in Brazil there are the federal impost on income and earnings of any nature, as well as the social contribution on net profits, in the terms of the Point 3, of the End Protocol, with text given by the Amendment of 2007 to the Convention, that states:

“Stay understood that the taxes covered by the Article 2, Paragraph 2, b) considers the Social Contribution on Net Profits (CSLL), created by the Law 7689, of December 15, 1988”


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