As of 1 January 1997, a Declaratory Act issued by the Brazilian Federal Reserve re-establishes a number of articles from the 1967 Brazil/Norway treaty. The following articles and paragraphs had become ineffective on 1 January 1992, but are now effective until 31 December 1999.
- Dividends: Art. 10(2) and (5);
- Interest: Art. 11, (2) and (3);
- Royalties: Art. 12, (2(b)); and,
- Methods to eliminate double taxation: Art. 24.
The next round of negotiations between Norway and Brazil for a revision of the 1980 income and capital tax treaty has been postponed until Brazil enacts a tax reform.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
For further information contact Carlos S Romero, Deloitte Touche Tohmatsu, Sao Paulo, Brazil on Tel: +55 11 257 0122, Fax: +55 11 258 8456