Brazil Publishes Ruling that Insurance Premiums Treated as Business Profits Under Tax Treaty with Norway
Brazil has published Ruling No. 138 of 20 September 2021 regarding the treatment of insurance premiums paid for insuring maritime vessels and equipment by a company in Brazil to a company in Norway under the 1980 Brazil-Norway tax treaty, given that such payments are not specifically addressed in the treaty. While it was considered whether insurance premium payments may qualify as payments for…
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