In a Private Letter Ruling, Brazil tax authorities ruled that payments abroad for the right to commercialize or distribute software in Brazil should be treated as royalties for tax purposes.A distinction was drawn between the right to distribute and the right to use the software.Taxpayers in Brazil with similar facts will want to consider how the analysis described in this ruling might apply to their situations. In June 2024, Brazil tax authorities (RFB) published Private Letter Ruling ("Solução de Consulta" in Portuguese) No. 177 dated 24 June 2024 (the Ruling), which addresses the tax treatment of remittances abroad for the right...