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Brazil: Protocol updates income tax treaty with Argentina

Brazil: Protocol updates, income tax treaty

A Protocol amending the income tax treaty between Brazil and Argentina has been approved by Brazil, with the late August 2018 publication of Decree nº. 9482/18.


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Among the provisions in the Protocol are measures reflecting certain standards of the base erosion and profit shifting (BEPS) project that generally addresses certain abusive practices in international structures. There are also measures in the Protocol providing for:

  • Reduced rates of income tax on payments of dividends, interest, or royalties (rates of 10% or 15%)
  • Concerning double taxation, a credit system in Brazil replacing the exemption of dividends of companies from the same corporate group in Argentina, and in Argentina, an exemption for certain types of taxable profits in Brazil
  • A “limitation on benefits” clause
  • Rules concerning permanent establishments (for instance, maintenance of a fixed installation with the sole purpose of developing an auxiliary and preparatory activity is not a permanent establishment)


Read a September 2018 report (English) or (Portuguese) prepared by the KPMG member firm in Brazil

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