General Office of the National Treasury's Attorney changes position on the application of tax treaties on outbound payments for technical services without transfer of technology

The General Office of the National Treasury's Attorney (Procuradoria-Geral da Fazenda Nacional - PGFN) recently changed its position on the application of tax treaties for the avoidance of double taxation on outbound payments for the rendering of technical services without transfer of technology.
In the past, the PGFN and the Federal Revenue Office (Receita Federal do Brasil - RFB) published Normative Opinion 776/2011 and Declaratory Act 1/2000 providing, in a nutshell, that tax treaties signed …