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Brazil and the Netherlands Agree on Treatment of Brazilian Interest on Net Equity under Tax Treaty

07 April 2022

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Treaty Development

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Brazil-Netherlands

On 4 April 2022, the Netherlands published a competent authority agreement with Brazil concerning the treatment of Brazilian interest on net equity (juros sobre o capital próprio - JCP) under the 1990 tax treaty between the two countries. The agreement was signed by Brazil on 3 December 2021 and by the Netherlands on 29 August 2021 to confirm that the competent authorities agree on the interpretation issued by the Dutch authorities in Decree No. 2020-14853. --- COMPETENT AUTHORITY AGREEMENT The competent authorities of Brazil and the Netherlands (hereinafter: the 'Competent Authorities') have reached the following mutual agreement (hereinafter: 'Competent Authority...