Treaty between Brazil and Canada, and between Brazil and Germany – Brazilian court decision on tax treaty treatment of remuneration of technical services
On 26 June 2009, the Federal Court of the 4th Region (second level of the federal judicial courts) confirmed that Brazil would not have the right to impose withholding tax on the "remuneration of technical services" or "service revenue" (the payments) that do not involve the transfer of technology provided by companies located in Canada and Germany to a Brazilian resident company u…
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