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一、序言尽管巴西不是OECD成员国,但OECD的相关倡议和行动依然对巴西产生了一定影响。近年来,遵循OECD《有害税收竞争(1998)》报告精神,巴西税法对避税港和优惠税制等相关规定频繁做出调整,涉及资本弱化、转让定价、利息扣除等,以防范相关避税行为或架构。最近,巴西对受控外国企业规则进行了调整,对避税地和优惠税制进行了区分,从而对此前允许合并扣除的情形做出了限制。税基侵蚀与利润转移(BEPS)项目的实施,也成为巴西推动
I. Preface Although Brazil is not a member of the OECD, the relevant OECD initiatives and actions still have some impact on Brazil. In recent years, following the spirit of the report of the OECD “Harmful Tax Competition (1998)”, the Brazilian tax law has frequently adjusted the relevant provisions on tax havens and preferential tax regimes, involving capital weakening, transfer pricing and interest deduction to prevent related tax avoidance activities or structures . Recently, Brazil adjusted the rules governing controlled foreign enterprises by distinguishing between tax havens and preferential tax regimes, thereby limiting the previously permitted merger deductions. The implementation of the Tax Base Erosion and Profit Transfer (BEPS) project has also been promoted by Brazil