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.
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