Tag: Trading companies

Brazil vs Macopolo, July 2014, Supreme Tax Appeal Court, Case no 9101-001.954

Brazil vs Macopolo, July 2014, Supreme Tax Appeal Court, Case no 9101-001.954

The case involved export transactions carried out by a company domiciled in Brazil, Marcopolo, manufacturing bus bodies (shells) which were sold to subsidiary trading companies domiciled in low tax jurisdictions (Jurisdição com Tributação Favorecida). The trading companies would then resell the bus bodies (shells) to unrelated companies in different countries. The tax authorities argued that the sale of the bus bodies to the intermediary trading companies carried out prior to the sale to the final customers lacked business purpose and economic substance and were therefore a form of abusive tax planning. The Court reached the decision that the transactions had a business purpose and were therefore legally acceptable. Click here for translation Brazil vs M 2014 ... Continue to full case