Brazil Establishes Tax Settlement Program Regarding Withholding Tax on Capital Gains and Other Income Earned by Non-Resident Investors

Brazil's Federal Revenue Service has announced the publication of Joint Transaction Notice PGFN/RFB No. 4/2026, issued jointly with the Attorney General's Office of the National Treasury. The Notice establishes a tax settlement program regarding withholding tax on capital gains and other income earned by non-resident investors.

The settlement program is available to taxpayers with pending administrative or judicial disputes concerning withholding tax on non-resident investor earnings at th…