OrbitaxBrazilian Court Holds Payments for Procurement Services Not Involving Transfer of Technology May Not be Treated as Royalties
|Treaty Development|Brazil-Belgium
A Brazilian Federal Court of Appeals has reportedly issued a decision concerning the treatment of payments for procurement services under the 1972 Belgium-Brazil tax treaty as amended by the 2002 protocol. In particular, the decision concerns the provision added by the 2002 protocol that Article 12 (Royalties) paragraph 3 (definition of royalties) covers payments received for technical assistan…
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