Brazil Official Gazette Consultation Solutions Clarifying Agricultural, Dividend Income for Individuals under DTA With Uruguay

The Brazilian Official Gazette May 21 published Consultation Solutions Nos. 83 and 84, clarifying the application of individual income tax (IRPF) to agricultural and dividend income under the 2019 DTA and protocol with Uruguay. The consultation solutions include measures clarifying that: 1) income earned by rural producers resident and domiciled in Brazil from agricultural exploitation of property in Uruguay may be taxed in both countries, subject to double taxation relief under the DTA; and 2) Brazil has taxing rights over dividends that Uruguayan companies pay to shareholders residing in Brazil, even when the shareholders have a permanent establishment (PE) in ...