The amended Brazil-China tax treaty (effective 14 June 2025) sets withholding tax rates for dividends, interest, and royalties.
The amending protocol to the 1991 income tax treaty between Brazil and China took effect on 14 June 2025.
Signed on 23 May 2022, it is the first amendment to the treaty and includes amendments to Articles 10, 11, and 12, introducing updated withholding tax rates.
For dividends: 10% for companies holding at least 10% of shares for 365 days, 15% otherwise, and 5% for specific government and state-owned entities.
For interest: 10% for specific long-term loans, 15% otherwise, and 0% for government-related entities.
For royalties: 15% for trademark use, 10% for other cases.
The protocol takes effect on 1 January 2026 for withholding and other taxes.
Earlier, Brazil’s Congress approved the amendment protocol to the Brazil-China income tax treaty on 5 May 2025.
