The Federal Brazilian Tax Authorities (RFB) published Solução de Consulta – Cosit 166/2018 on September 28, 2018 regarding the application of the reduced rate of 0% income withholding tax for international charter leasing payments. It states that this rate may apply on amounts as consideration for international charter leasing of boats/vessels, but the beneficiary must not be located in a jurisdiction considered a tax haven. In addition, the reduced rate of 0% may still apply where the international remittance is made by a third party located in Brazil directly, rather than the entity that is performing the leasing.
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