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Brazil Publishes Ruling that Insurance Premiums Treated as Business Profits Under Tax Treaty with Norway

|Treaty Development|Brazil-Norway
Brazil-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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