Tax ruling clarifies application of CIDE on service fees paid to non-resident related company under CSA

Private ruling No. 43/2008, issued by the Fourth Regional Office of the Federal Revenue Service (which has jurisdiction in certain states in north-eastern Brazil), was published in the Official Gazette of 9 September 2008. In the ruling, the tax authorities made it clear that service fees paid by a Brazilian resident entity to its non-resident related party are subject to the contribution on services and royalties (the so-called CIDE - Contribuição de Intervenção do Domínio Econômico) at a…