Aplicação de tratados internacionais contra a bitributação

The book analyses the qualification problems arising from the application of double tax conventions to joint venture partnerships. The first chapter describes the topic and its relevance. The second chapter looks into the concept of conflicts of qualification and its role in the law of conflicts and international tax. The third, fourth and fifth chapters focus on tax treaties, their interpretation, and conflicts of qualification under tax treaties, respectively. The last chapters analyse the types of joint ventures and characteristics of partnerships and provide specific considerations on the application of double tax conventions to partnerships.