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Treaty between Brazil and France – Brazilian court decision on tax treaty treatment of remuneration of technical services

|Treaty Development|Brazil; France
Brazil; France

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On 15 April 2010, the Federal Court of the 2nd Region (second level of the federal judicial courts) confirmed that Brazil has the right to impose withholding tax on the remuneration for services provided by a company located in France to a Brazilian resident company under the Brazil-France tax treaty.

(a) Background. As is the case with Brazil's treaties …

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