After close to 27 years of proceedings, Brazil’s Supreme Court ruled on 5 August 2020 on a case initiated by Swedish auto manufacturer Volvo in 1993. The proceedings contest the imposition of dividend withholding tax on distributions by Volvo Brazil to its Swedish parent company under the then applicable Law 8383/91, when similar dividend distributions to Brazilian residents were exempt from the withholding tax. Volvo claimed a similar exemption from dividend withholding tax pursuant to Art. 24(1) (non-discrimination clause) of the Brazil-Sweden tax treaty of 25 April 1975. The relevant clause provides that "The nationals [including legal entities] of a...