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The New Interpretation of Brazilian Federal Revenue regarding WHT on the Payment of Services Abroad
Brazilian Federal Revenue (BFR) published Normative Instruction 1,455 (IN 1,455/14), comprising the levy of withholding tax (WHT) on different types of income resulting from cross-border payments made to nonresidents. IN 1,455/14 confirmed the tax authority understanding regarding the levy of WHT at 15% rate on technical services, and also provided a broader definition of technical services in comparison with IN 252/02, including consulting services, services provided by companies and services relying on automated means. According to IN 1,455 is considered technical: “the service which execution relies on specialized technical knowledge or involving administrative assistance or consulting services performed by independent professionals or companies, or relying on automated means with clear technological content”. Jointly with IN 1,455, BFR issued on 20th June, an Interpretative Declaratory Act (ADI 5/2014) comprising the Tax Authorities understanding of withholding income tax levied on the import of services when the service provider is resident in a jurisdiction with Double Tax Treaty (DTT) with Brazil.
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ADI 5/2014 sets forth the tax treatment applicable to income paid, credited, delivered, employed or remitted by Brazilian entities to non-resident individuals or legal entities in consideration for technical services and technical assistance with or without transfer of technology. In this way, the amounts remitted abroad shall receive the treatment set forth in the DTT. It is noteworthy that although the tax authorities have recognized the applicability of article 7 of DTTs (business profits) to the income arising from the provision of services, ADI 5/2014 determines that the applicability of article 7 is secondary, and only admitted when the income may not be qualified as royalties or income of independent professions or of professional or personal services, by the applicable DTT. In summary, if the requirements are met and the remittance abroad fall under Article 7 of the DTT, WHT shall not be triggered on the remittances paid by a Brazilian entity to entities resident in jurisdictions with tax treaty with Brazil.
The New Interpretation of Brazilian Federal Revenue regarding ... - WTS
252/02, including consulting services, services provided by companies and services relying on automated means. According to IN 1,455 is considered technical: ...
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