On 27 August 2020, the Netherlands published Decree No. 2020-14853 from the State Secretary of financing 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 Decree provides that JCP is classified as a benefit derived from shares for Dutch tax purposes, which previously qualified for the Dutch participation exemption. From 1 January 2016, however, the participation exemption no longer applies for JCP since it can be deducted from the Brazilian tax base. Although JCP no longer qualifies for the participation exemption, and is...