Brazilian withholding tax does not apply to premium payments made by a Brazilian resident company to a Norwegian insurance company without a permanent establishment. This ruling is good news for foreign insurance companies that receive premium payments from Brazilian resident customers as those payments may be exempt from withholding tax where a double-tax treaty is available. In Private Letter Ruling (PLR) No. 138 of 20 September 2021, the Brazilian Tax Authority provided welcome guidance as it ruled that, under the rules of the Brazil-Norway double tax treaty, withholding tax does not apply to insurance premiums paid to a Norwegian insurance...