The income tax treaty between Brazil and Uruguay was signed on 7 June 2019. The treaty is the first of its kind between the two countries and provided for the following withholding tax rates:

• Dividends - 10% if the beneficial owner is a company that has held at least 25% of the paying company's capital for 365-days period including the date of payment; otherwise, 15%
• Interest - 15%
• Royalties -…