In the first ten days of May, Brazil signed Double Taxation Convetions with Singapore and Switzerland. The new treaties were heavily influenced by the 2017 version of the OECD Model Convention, with an important tax-avoidance component, and in line with the BEPS project recommendations. In addition, the new Brazilian treaties contain a new specific article for income originated from the provision of technical services, which will be taxable in the State of residence with the possibility, also, that the source State may tax that income at a rate of up to 10%.
According to the Federal Revenue Service, the agreement with Switzerland is among the main demands from the Brazilian private sector, since Switzerland occupies the sixth position among the countries that most invest in Brazil, with amounts around US $ 22 billion. Singapore also has significant participation in the Brazilian economy, particularly in the oil and gas, infrastructure, real estate, agriculture and transportation sectors.
These treaties still need to be ratified and enacted to produce effects in Brazil, a process that may take a few more years. We will follow the progress of the legislative process of these treaties and return to the subject in due course.