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Brazil Publishes Ruling on Foreign Tax Credit for Additional Tax Imposed by Italy on Non-Arm's Length Interest Payment

|Treaty Development|Brazil-Italy
Brazil-Italy

Brazil has published Ruling No. 15 of 19 February 2025 regarding the availability of a foreign tax credit for additional tax payable in Italy as a result of a transfer pricing adjustment. The ruling concerns a Brazilian taxpayer that provided a loan to a related party in Italy, which was repaid in full, with interest. This was subject to 15% withholding tax in accordance with the 1978 Brazil-I…

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