On 10 November 2016, Brazil's Federal Revenue Department (RFB) announced that Normative Instruction RFB No. 1669/2016 had been published in the Official Gazette. The Normative Instruction sets out the mutual agreement procedures (MAP) under Brazil's tax treaties in line with the minimum standard for dispute resolution developed under BEPS Action 14.
The Normative Instruction provides that a taxpayer may apply for MAP when it considers that the actions of one or both of the Contracting States…