The Brazilian Federal Revenue Service (Receita Federal do Brasil, RFB) in a private ruling issued on 7 August 2020 (Private Ruling 99,006/2020) addressed the tax treatment of fees for technical services and technical support paid from Brazilian sources to Finnish beneficiaries. The Revenue Service took the position that in conformity with the provisions of the Brazil-Finland tax treaty of 2 April 1996, fees for technical services and technical support cannot be characterized as royalties and, therefore, are not subject to withholding tax when paid to Finnish residents. The solution holds regardless of whether or not the payer and the recipient...