Brazil has published Private Ruling No. 9035 of 19 December 2018 in the Official Gazette, which clarifies the treatment of software licensing fees under the 2002 income tax treaty with Israel. The Ruling provides that licensing fees paid to an Israeli domiciled company for the use of software qualify under Article 12 (Royalties) of the treaty as consideration for the use of, or the right to use, any copyright and, therefore, are eligible for the 10% treaty withholding rate. Licensing fees pa…