Brazil has published Private Ruling 351 of 29 June 2017, which clarifies the tax treatment of branches (subsidiaries) in Brazil of foreign legal entities, and in particular, a foreign legal entity that is a non-profit. The ruling includes that branches of non-resident in Brazil are to be treated the same as resident companies. As such, a branch in Brazil of a foreign non-profit will be entitled to the same tax exemptions provided to a resident non-profit legal entity, and are only required t…