The Brazilian Revenue Service, in Declaratory Interpretative Act 07 (ADI 07/2014) released August 15, has modified its position concerning the tax treatment of amounts paid by a Brazilian residents to foreign legal entities for the provision of infrastructure for data processing and storage with remote access, deeming such payments to be payments for the provision of services, writes EY in an August 20 tax alert. For a discussion of the new guidance, see EY.
