In light of this Private Letter Ruling, investors may want to reevaluate their foreign investment structures into Brazil, taking into consideration their global footprint and the potential availability of tax treaty benefits.In Private Letter Ruling (Solução de Consulta) No. 150 (dated 22 September), the Brazilian Tax Authority (RFB) confirmed that the capital gain generated by a Portuguese resident company on the sale of its equity interest in a Brazilian company is subject to nonresident capital gains tax at the 15% rate by applying the “most-favored-nation clause” of the Brazil-Portugal double tax treaty.BackgroundUnder Brazilian domestic law, capital gains realized by nonresidents...