A recent judgment of the Hague Court of Appeals was released on 28 May 2025 concerning the treatment of Brazilian interest on net equity (juros sobre o capital próprio - JCP) under the 1990 Brazil-Netherlands tax treaty. The main issue was whether JCP should be treated as interest under the treaty, which would entitle a Dutch recipient to a 20% tax credit, or should be treated as dividends, which would entitle a Dutch recipient to a 25% tax credit. In its judgment the Court of Appeals determ…