Brazil has published Private Ruling No. 2004 of 12 March 2019 in the Official Gazette, which concerns the taxation of payments for technical services and technical assistance made by companies resident in Brazil to companies resident in France. The ruling provides that under the 1971 Brazil-France tax treaty, such payments are not subject to withholding tax. This is in line with Brazil's general position that if a treaty does not specifically address the taxation of technical services/assist…