No income tax withheld on technical services and support on payments to Finland

Written by | Tax and Customs

On 7 August 2020, the Brazilian Federal Revenue Department issued a new ruling (Private Ruling 99,006/2020) addressing the double tax agreement between Brazil and Finland.

The Ruling specifically dealt with Brazil’s withholding income tax on technical and support services. The Department decided that “on remittances for payments for technical services and support provided by legal entities located in the Republic of Finland, regardless as to whether they are part of the same corporate group, no income tax is withheld”.

Importantly, the Ruling applies if the services criteria set out in the Brazil-Finland Double Tax Agreement and the Department’s definitions for those types of services.

This ruling confirms Binding Ruling 109/2016.

For general information on the taxation of imported services, click here.

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Last modified: September 21, 2020