The Brazilian Senate is currently considering amendments to Law 9,249/1995 that would impose a withholding tax on dividends paid by a Brazilian resident to a nonresident beneficial owner. Under Law 9,249/1995 an exemption has applied since 1996.
The amendments would adjust the wording of the law so that dividend payments made by a Brazilian company to Brazilian resident beneficial owners would remain exempt, but dividend payments to a nonresident beneficial owner would only be exempt if the …