Brazil has published Private Ruling No. 6003 of 2 April 2020 in the Official Gazette, which clarifies the treatment of software licensing fees under the 1975 income and capital tax treaty with Austria. The Ruling provides that licensing fees paid to an Austrian domiciled company for the use of software qualify under Article 12 (Royalties) of the treaty as consideration for granting the use of copyright and, therefore, are eligible for the 10% withholding rate provided under paragraph 2(a) of…