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Brazil Cross-border Payments under Cost Sharing Agreement for Software License Taxed as Royalties

|Approved Changes|Brazil
Brazil

Brazil has published Private Ruling 442 of 18 September 2017, concerning the withholding tax treatment of payments made by a Brazilian resident company to its Italian parent under a cost sharing agreement for a foreign software license acquired by the parent from a third party (software used by the Brazilian company). The ruling provides that because the payment is for the reimbursement of the…

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