Brazil has published Ruling No. 15 of 19 February 2025 regarding the availability of a foreign tax credit for additional tax payable in Italy as a result of a transfer pricing adjustment. The ruling concerns a Brazilian taxpayer that provided a loan to a related party in Italy, which was repaid in full, with interest. This was subject to 15% withholding tax in accordance with the 1978 Brazil-Italy tax treaty. The Brazilian taxpayer recognized and paid Brazilian corporate income tax and CSLL (Social Contribution on Net Profit) on the interest income in Brazil, claiming a credit for the Italian tax...