Using Treaties and Holding Companies for Latin American Tax PlanningAmanda D. Johnson Collection of articles providing an insight in the current status of tax treaties in Latin American and Caribbean countries, and dealing with holding companies and technical assistance, royalty and service payments. |
Contents
Tax Treaty Planning in Latin America | 7 |
Tax Treaties of Brazil | 27 |
The Income Tax Treaties of Chile | 55 |
The Income Tax Treaties of Mexico | 73 |
New Commentaries to the OECD Model Convention | 87 |
Other editions - View all
Using Treaties and Holding Companies for Latin American Tax Planning Amanda D. Johnson No preview available - 2005 |
Common terms and phrases
15 percent activities Advogados e Consultores America Andean Pact apply Argentina Avoidance of Double Baker & McKenzie Barbados benefits Brazil business profits Canada capital gains CFC rules Chile Chilean holding company clause Commentaries Contracting corporate income tax Denmark distribution dividends paid domestic law Double Taxation DTA's Ecuador effect entity exempt financing Fiscal foreign gross holding company regime impose international tax investments Jamaica John Salerno jurisdiction Machado Associados Advogados member countries Mexican Mexico Miguel Valdes Model Convention negotiating Netherlands nonresidents Norway OECD Model ownership paragraph partner Paul Tadros percent withholding tax permanent establishment PricewaterhouseCoopers Protocol provisions PTR rules right to tax shareholder shares software payments Spain Spanish specific subject to withholding subsidiaries Sweden Switzerland tax authorities tax haven tax purposes tax sparing tax treaties tax treaty network taxable taxpayer technical assistance services trade Trinidad and Tobago Uruguayan Venezuela withholding rate withholding tax rate