[Elton Rodrigues Teixeira Lima]

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I have a friend who is a director and has been working in Spain for 2 years. He has tax residency in both countries and has dual citizenship (Brazilian and Spanish). During this time there he never declared his income tax in Brazil as an individual but only in Spain and my question is whether he would have had to declare this difference of 3.5% (because I know that in Spain the individual tax is 24% and in Brazil it is 27.5%)? If he collects the difference of 3.5% in this 2-year period that he stayed in Spain with tax residence in Brazil too, should he file a rectifying tax return? What sanctions could he face? And what should he do about Spain (should he take any action?)? Sorry for the lot of questions, it's just that I'm very interested in the subject and I know that Brazil has an agreement with Spain that is in force and serves to avoid double taxation (by the way, do you know if this agreement is statute-barred?).
Thank you

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