Executive summary
On 27 August 2020, the Dutch State Secretary of Finance published a decree on the qualification of Brazilian Interest on Net Equity (INE) payments (the Decree), for Dutch corporate income tax (CIT) purposes and for the application of the Tax Agreement between Brazil and the Netherlands (BR-NL tax treaty). By means of this Decree, the State Secretary of Finance has clarified the position of the Dutch Ministry of Finance regarding the classification of the INE payments as either d…