On 21 October 2014, the Brazilian Federal Administrative Court ruled on the compatibility of Brazil's CFC rules with the country's tax treaties with the Netherlands and Argentina in regard to income tax and the social contribution on net profits (CSLL). The case involved a Brazilian resident company that did not pay income tax and CSLL on the profits of its affiliated companies in the Netherlands and Argentina because, as the company argued, the CFC rules would conflict with the application of the tax treaties signed with those two countries. The tax authorities argued that tax was due because the taxation...