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Brazil Publishes Ruling on MFN Clause for Capital Gains on Shares Under Tax Treaty with Portugal

|Treaty Development|Brazil-Portugal
Brazil-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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