Brazil has published Private Ruling 316 of 20 June 2017, which clarifies the payment obligations for social security contributions (PIS/COFINS) on technical service and technical assistance payments to non-residents in connection with royalty payments. The ruling provides that royalty payments on their own are not subject to PIS/COFINS, but technical service/assistance payments are. Where the royalties and technical service/assistance are covered under a single contract and the payment amoun…