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Brazilian Revenue Service Holds No Withholding Tax on Technical Service Fees under Treaty with Finland

|Treaty Development|Brazil-Finland
Brazil-Finland

The Brazilian Federal Revenue Service (Receita Federal do Brasil, RFB) in a private ruling issued on 7 August 2020 (Private Ruling 99,006/2020) addressed the tax treatment of fees for technical services and technical support paid from Brazilian sources to Finnish beneficiaries. The Revenue Service took the position that in conformity with the provisions of the Brazil-Finland tax treaty of 2 Apr…

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