Brazil has published Private Ruling 7047 of 24 July 2019 in the Official Gazette concerning the taxation of donations made to non-residents. The ruling provides that where amounts are remitted as a donation to a natural or legal person resident or domiciled abroad, the donation is subject to withholding tax at a rate of 15%. In cases where the beneficiary is resident or domiciled in a jurisdiction with favored taxation (a low-tax jurisdiction), the withholding tax rate is increased to 25%.
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