Brazil has published Private Ruling No. 82 of 20 March 2019 in the Official Gazette, which concerns the tax credit for royalties provided under the 1974 Brazil-Spain income tax treaty. For the purpose of the credit method provided for under Article 23 (Methods for Elimination of Double Taxation), tax on royalties shall in all cases be deemed to have been paid at the rate of 25%. The ruling clarifies that this credit applies even if no tax has actually been paid. The ruling also clarifies tha…