Brazil has published Ruling No. 150 of 22 September 2021 regarding the taxation of capital gains derived by a Portuguese company from the sale of a direct investment (equity interest) in the shares of a Brazilian company. Under Article 13 (Capital Gains) of the 2000 Brazil-Portugal income tax treaty, capital gains from any property can generally be taxed in both Contract States except for gains from the alienation of ships or aircraft operated in international traffic, etc. As such, capital gains derived from the sale of the shares would be subject to domestic withholding at the progressive rates of 15%...