Brazil’s tax authorities, in guidance released June 20, have made a “landmark change” to the withholding tax treatment of outbound payments for technical services and technical assistance in cases covered by a tax treaty, writes Deloitte in a June 27 report. For analysis of the new guidance, Interpretative Act No. 5/2014 (ADI RFB 5/2014), which can be applied retroactively, see report by Deloitte.
