The Brazilian tax authorities issued on December 23 2004 the Interpretation Declaratory Act (ADI 27, which is an official interpretation from the Brazilian tax authorities), setting forth their understanding in connection with payments of dividends, royalties and service fees made under the Brazil-Spain Convention for the Avoidance of Double Taxation (the Tax Treaty)
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Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort