The amending protocol to the 1991 income tax treaty between Brazil and China entered into force on 14 June 2025. The protocol, signed 23 May 2022, is the first to amend the treaty and includes the following main changes:
- The title and preamble are replaced in line with BEPS standards;
- Article 1 (Persons Covered) is replaced, including the provision that income derived by or through an entity or arrangement that is treated as wholly or partly fiscally transparent under the tax law of either C…