Brazil Publishes Ruling on MFN Clause for Capital Gains on Shares Under Tax Treaty with Portugal
Brazil has published Ruling No. 150 of 22 September 2021 regarding the taxation of capital gains derived by a Portuguese company from the sale of a direct investment (equity interest) in the shares of a Brazilian company.
Under Article 13 (Capital Gains) of the 2000 Brazil-Portugal income tax treaty, capital gains from any property can generally be taxed in both Contract States except for ga…
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