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An issue frequently raised by Brazilian parent companies investing abroad is what level of ‘local substance’ is required for a European holding company set up by a Brazilian group. Unfortunately, there are no hard and fast rules. This article sets out some key points to consider based on international tax principles, EU tax considerations, local tax considerations in typical EU member states and our understanding of Brazilian tax concerns. (September 2010).
To access this article, please email@example.com
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