By Alex Jorge, Renato Lopes da Rocha, Randall Fox and James Dalley
Brazil has entered into 33 bilateral tax treaties, namely those with Argentina, Austria, Belgium, Canada, Chile, China, Czech Republic, Denmark, Ecuador, Finland, France, Hungary, India, Israel, Italy, Japan, Luxembourg, Mexico, Norway, the Netherlands, Peru, Philippines, Portugal, Russia, Slovakia, South Africa, South Korea, Spain, Sweden, Trinidad and Tobago, Turkey, Ukraine and Venezuela. Under those treaties, taxpayers may request a Mutual Agreement Procedure (MAP) if taxation that has occurred (or is likely to occur) that is not in accordance with the relevant treaty.
In addition to Brazil’s tax treaties, Brazil’s domestic tax law also provides for MAPs. In November, Brazil’s Internal Revenue Service published a manual on MAP setting out the process through which taxpayers can request assistance from the Revenue, including the contents of the MAP application and the possible outcomes resulting from a request for MAP assistance.
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