Brazil has published Private Ruling 400 of 5 September 2017, which clarifies the exemption for dividend income from Argentina provided under the 1980 income tax treaty between the two countries. The exemption is included in paragraph 2 of Article XXIII (Methods for the Elimination of Double Taxation), which provides that "Dividends which are paid by a company which is a resident of Argentina to a company which is a resident of Brazil and holds more than 10 per cent of the capital of the comp…