The Brazilian tax authorities issued on 20 March 2006 Declaratory Interpretative Act 3 concerning the Brazil-Korea income tax treaty of 7 March 1989 (which serves as an official interpretation issued by the Brazilian tax authorities), setting forth their understanding in connection with payments of dividends, royalties and technical service fees under the treaty.
As a result of the application of the most favoured nation clause included in the protocol to the treaty and according …