Brazil and Spain Agree Brazilian Interest on Net Equity Constitutes Interest Under Tax Treaty

Spain's Ministry of Finance has published notice explaining that, through an exchange of notes signed with Brazil on 25 November 2025 and 12 March 2026, it has been agreed that Brazilian interest on net equity (juros sobre o capital próprio - JCP) is deemed to constitute interest for the purposes of the definition of interest as per paragraph 5 of Article 11 (Interest) of the 1974 tax treaty between the two countries. As such, JCP will be taxed as interest under the treaty, according to the …