Official Gazette of 11.6.2002
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Regulates the tributary treatment applicable to the profit and dividends derived from investments in Spain. |
The FEDERAL REVENUE SECRETARY, in the use of the attribution given to him by proposition III of Article 209 of the Intern Regiment of the Federal Revenue Service, approved by the Ministerial Rule nº 259, from 24 of August of 2001, and having regard to the Convention for Avoiding Double Taxation and Prevention of Fiscal Evasion with Respect to Taxes on Income between Brazil and Spain, promulgated by the Decree nº 76.975, from 2 of January 1976, as well the arranged in Articles 25 and 35 of the Law nº 9.249, from 26 of December 1995 declares:
Art. 1 Are submitted to the incidence of taxes on income the profit and dividends received by residents or domiciliaries in Brazil, deriving from the participation in “Entidad de Tenencia de Valores Extranjeros"/ETVE, regulated by the Spanish Law of the Societies Tax, not applying to the arranged in paragraph 4º of Article 23 of the Convention for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with Respect to Taxes on Income between Brazil and Spain, promulgated by the Decree nº 76.975, from 1976.
Art. 2 The announced in the previous Article is applied to the taxable events occurred from January 1st, 1996.
EVERARDO MACIEL