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Brazilian Federal Regional Court Rules on Treatment of Payments for Technical Services Under Tax Treaties with Argentina, Germany, and Spain

|Treaty Development|Brazil-Argentina-Germany-Spain
Brazil-Argentina-Germany-Spain

Brazil's Federal Regional Court of the Third Region recently issued a ruling regarding cases involving the treatment of payments abroad for technical services/assistance under Brazil's tax treaties with Argentina, Germany, and Spain. In general, the position in Brazil is that if a treaty does not specifically address the taxation of technical services/assistance as royalties or the service/assistance, then the provisions of the treaty article on business profits will apply (i.e., withholding …

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