Agreement between Brazil and Israel to avoid double taxation and prevent income tax evasion

Legislative Decree 931 as of September 15, 2005 approved the wording of Agreement between Brazil and Israel to avoid double taxation and prevent income tax evasion. Said Agreement was enacted by Decree 5,576 as of November 8, 2005. 
The Agreement came into force, worldwide, on September 21, 2005, pursuant to paragraph 1 of article 29 thereof.

      The Agreement shall apply to individuals residing in one or both Contracting State Members, that is, Brazil and Israel.

      In case of Brazil, the agreement applies to the federal income tax and, for Israel, taxes deriving from the Income Tax Law and supplementary legislation (including the corporate tax and capital gain tax), as well as taxes levied on capital gains resulting from disposal of real property pursuant to Rural Property Tax Law.     

     The Agreement provides for the tax treatment of Real Estate Revenues (article 6), Companies’ Profits (article 7), income deriving from Air and Maritime Transportation (article 8), Associate Companies (article 9), Dividends (article 10), Interest (article 11), Royalties (article 12), Capital Gains (article 13), Independent Professional Services (article 14) and Dependent Professional Services (article 15).
     
      In addition, the Agreement provides for the following issues: Management’s compensation (article 16), Artists and Sportspersons (article 17), payment of Annual Fees and Pensions (article 18), Public Offices (article 19), Professors and Researchers (article 20), Students and Trainees (article 21) and Other Income not covered by other articles of the Agreement (article 22), Methods to Eliminate Double Taxation (article 23), Non-Discrimination (article 24), Benefit Restrictions (article 25), Amicable Proceeding (article 26), Exchange of Information (article 27) and Members of Diplomatic Missions and Consulate Service Centers (article 28).

      The Agreement provisions shall take effect: