Brazil has published Private Ruling 316 of 20 June 2017 on royalty and technical service payments and payments for services under cost sharing agreements. The ruling explicates the accountabilities for social security contributions (PIS/COFINS) on technical service and technical support payments to non-residents in connection with royalty payments. According to the ruling, royalty payments on their own are not subject to PIS/COFINS, but technical service payments are.
«
Qatar authorizes to sign a DTA with Argentina
Related Posts

Brazil: Senate approves tax treaty protocol with China
Brazil’s Senate has approved the protocol amending the Brazil-China Income Tax Treaty (1991) through Draft Legislative Decree No. 343/2024 on 8 April 2025. Signed on 23 May 2022, this protocol is the first amendment to the treaty. It will come
Read More
Brazil updates rules on social contribution top-up tax for Pillar 2
Brazil has issued Normative Instruction RFB No. 2.259 of 24 March 2025, which amends the regulations for the Additional Social Contribution on Net Profit (CSLL) contained in Normative Instruction RFB No. 2,228 of 3 October 2024. The Additional
Read More
Brazil ends COVID-19 era support for events sector
Brazil has announced the conclusion of the Emergency Program for the Resumption of the Events Sector (PERSE) through RFB Executive Declaratory Act No. 2 of 21 March 2025, which was published in the Official Gazette. The PERSE program, established
Read More
Brazil: Chamber of Deputies consider detox tax on digital platforms
Brazil's Chamber of Deputies is reviewing a draft bill on 18 March 2025 to introduce a digital detox contribution (CIDE-Detox Digital). As per the legislation, a 1% contribution tax would apply to companies with digital platforms earning over BRL
Read More
Brazil: Chamber of Deputies approve pending protocol to tax treaty with Colombia
Brazil's Chamber of Deputies has passed Draft Legislative Decree No. 311/2024, which ratifies the pending income tax treaty with Colombia on 27 March 2025. The treaty has been presented to the Senate for final approval. Signed on 5 August
Read More
Brazil to tax overseas corporate profits
Brazil's government has proposed imposing a 10% tax on corporate profits and dividends sent abroad on 17 March 2025 to offset the revenue loss from expanding the tax exemption brackets for low-income individuals. According to the country's
Read More