On 9 June 2021, the Brazilian Government issued Decree No. 10,714/2, which concludes the ratification process of the double taxation treaty between Brazil and Switzerland.
The new DTA, which will come into force from 1 January 2022, promotes economic relations between Brazil and Switzerland. It also takes into account the results of the G20/OECD project aimed at combating base erosion and profit shifting by introducing an anti-abuse clause.
Finally, the agreement contain an administrative assistance clause in accordance with the international standard for the exchange of information upon request.
Here below, the main aspects of the treaty:
Income | Maximum Rate – Withholding Tax |
Dividends (article 10) | 10%-15% |
Interest (article 11) | 15% |
Royalties (Article 12) | 10%-15% |
Technical Services (Article 13) | 10% |