Disparity between the US and Brazil’s approach to royalties increases risk of double taxation

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


Disparity between the US and Brazil’s approach to royalties increases risk of double taxation

As a result of Brazil’s unique policy to prevent erosion of the tax base, companies often face double taxation.

The pending case before the US Tax Court (Docket 5816-13), 3M Co. et al. v. Commissioner, brings this issue into the spotlight. In this case the US Internal Revenue Service (IRS) claims that 3M should be charging higher royalties for the trademark. 3M claims that it is bound by Brazilian legal requirements. The IRS argues that the amount charged is not at arm’s-length, because there should be a 6% royalty rate over the net sales of manufactured products.

In Brazil, outbound royalty payments are not subject to transfer pricing rules. Instead, there are fixed limits for deductibility and remittance requirements that must be observed. First, all the contracts must be submitted for analysis by the National Industrial Property Institute (INPI) and be registered with the Brazilian Central Bank.

Second, royalties related to the use of patents of invention, manufacturing formulas or processes, and expenses for technical, scientific, administrative or similar assistance are, in most cases, limited to 5% of the net revenue from the sale of products covered by the licence agreement or service provision agreement, but for some of them the limitation is lower, depending on the company’s activity.

Royalties for the use of brands (industrial or trademarks) pertaining to any type of production or activity, when not involving use of a patent, manufacturing formula or process, are limited to 1% of the same revenue.

Technical, scientific, administrative and related fees are also subject to the same requirements for deductibility and remittance of royalties, except for the fact that they can only be deducted in the first five years of the company’s establishment or the application process. Deductions can be, renewed for another five years if it is proved to be necessary.

Brazil and the US do not have a double tax treaty or any alternative dispute resolution mechanism so the outcome of the 3M Case is very important for planning and tax compliance purposes for companies investing in Brazil.

By André Gomes de Oliveira (andre.oliveira@cbsg.com.br) and Francisco Lisboa Moreira (Francisco.moreira@cbsg.com.br)

more across site & shared bottom lb ros

More from across our site

Awards
It was also a memorable night for Baker McKenzie and its associated firms, after picking up 19 awards, including the coveted Asia-Pacific Tax Law Firm of the Year
Stocche Forbes Advogados, Utumi Advogados and Lobo de Rizzo Advogados have reached Tier 2 as competition intensifies in the region’s largest tax market
Ben Webster’s arrival represents a significant expansion of Withers’ London tax litigation practice, as the private client firm eyes further international growth
The combination swiftly builds on RSM’s addition of a new Lithuanian firm to its international network, signalling a European build-out
Tax teams must look beyond pillar two’s headline rules as R&D incentives and the US side-by-side deal create new strategic choices for multinationals, says Marta Pankiv of Tricentis
As funds work becomes more complex, Proskauer is betting that embedded tax expertise can strengthen its wider offering
The recently founded AI platform stands out in a crowded marketplace thanks to a compelling vision and friends in the right places
Advisers expect consumption tax reform to stay on course, but debt pressures could push the government towards tougher enforcement and incentive reviews
The firm demonstrated its sweet spot of litigation with an international twist with the recent win for the Danish tax authority…but it’s not a tax case
The recently formed firm has taken a break from hiring EY talent to expand its transactional tax and tax technology capabilities
Gift this article