Brazil has published Private Ruling 99004 of 15 April 2019 in the Official Gazette concerning the tax treatment of outbound payments made for rights over the sale or distribution of software to final consumers in Brazil that have been granted a license for the use of software. The ruling provides that such payments are considered royalties, and therefore subject to withholding tax at a rate of 15% (unless a tax treaty provides otherwise). However, such outbound payments are not subject to th…