• Provide for a structured analysis of the mechanisms for taxation of income derived from cross-border transactions.
  • Discussion of the interplay between income tax rules of different jurisdictions and the formation of a so-called international tax system.
  • Comprehension of the main Brazilian income tax rules applicable to cross border transactions, especially in relation to:
    • Outbound income flows earned by non-residents in inbound transactions;
    • Inbound income flows earned by residents outbound transactions;
    • Transfer pricing and other rules for allocation of taxable income within a group.