OrbitaxGuideline on unilateral modification of tax sparing credit not in breach of France–Brazil tax treaty
|Treaty Development|France-Brazil
The French Supreme Administrative Court held in a decision of 26 July 2006 that Guideline 14 A-7-97 of 15 December 1997 regarding tax sparing credits under the France-Brazil tax treaty of 10 September 1971 did not constitute an illegal interpretation of the tax treaty (Case No. 284930). Details of the decision are summarized below.
(a) Background. Guideline 14 A-7-…
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