On 19 June 2017, Brazil published private ruling No. 7014/2017 concerning the taxation of amounts paid, credited or remitted abroad for the right to market or distribute software for resell. The ruling clarifies that such outbound payments are considered royalties subject to the standard 15% withholding tax, but are not subject to the Contribution for Intervention in the Economic Domain (CIDE - 10%), unless the transaction involves a transfer of the corresponding technology (i.e., the softwa…