OrbitaxSupreme Federal Court issues decision on profits derived by foreign controlled and affiliated companies for corporate income tax purposes
|Approved Changes|Brazil
The Supreme Federal Court (Supremo Tribunal Federal, STF) gave its decision on 10 April 2013 in regard to the Direct Action of Unconstitutionality 2588 (AçãoDireta de Inconstitucionalidade 2588, ADI 2588). The STF also referred in its decision to Extraordinary Appeals (RecursosExtraordinários, REs) 611586 and 541090. Details of the decision are summarized below.
(a) Facts. The case concern…
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