A Brazilian Federal Court of Appeals has reportedly issued a decision concerning the treatment of payments for procurement services under the 1972 Belgium-Brazil tax treaty as amended by the 2002 protocol. In particular, the decision concerns the provision added by the 2002 protocol that Article 12 (Royalties) paragraph 3 (definition of royalties) covers payments received for technical assistance or the provision of technical services, and that the tax on remuneration for such assistance/serv…