On 4 April 2022, the Netherlands published a competent authority agreement with Brazil concerning the treatment of Brazilian interest on net equity (juros sobre o capital próprio - JCP) under the 1990 tax treaty between the two countries. The agreement was signed by Brazil on 3 December 2021 and by the Netherlands on 29 August 2021 to confirm that the competent authorities agree on the interpretation issued by the Dutch authorities in Decree No. 2020-14853.
---
COMPETENT AUTHORITY AGREEM…