A decision of Brazil’s Administrative Council of Tax Appeals (CARF) was reportedly published at the end of December 2019 in regard to the application of the substantial economic activity requirement that applies in relation to holding company regimes listed under Normative Instruction RFB No. 1037/2010 (list of low tax jurisdictions and privileged tax regimes). Inclusion in the list impacts several areas of Brazilian taxation, including withholding tax rates, the deductibility of expenses, th…