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

Tax teams are responding to usual client demand in the region, albeit with increased working from home flexibility, local sources indicate
A 120-plus-day delay to refunds would cost taxpayers almost $3bn in additional interest, the Cato Institute warned; plus indirect tax updates from February
The Office for Budget Responsibility’s pessimistic pillar two forecast accompanied the UK chancellor’s muted Spring Statement, dubbed ‘as dull as possible’ by one adviser
Digital tax reform is dissolving the old ‘temporal buffer’, forcing systems, institutions, and professionals to adapt as real-time reporting reshapes governance, capability, and compliance
Our first instalment features analysis of Deloitte’s landmark EMEA merger, Donald Trump’s Supreme Court tariff showdown and Venezuela’s tax evolution
While some believe it could have a positive effect on the wider advisory landscape, others argue that HMRC’s ‘red tape’ exercise won’t deter bad actors
The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos
The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week
Tom Goldstein, who was represented by US law firm Munger, Tolles & Olson, denied wilfully cheating on his taxes and blamed errors on his staff
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
Gift this article