On 27 August 2020, the Netherlands published Decree No. 2020-14853 from the State Secretary of financing 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 Decree provides that JCP is classified as a benefit derived from shares for Dutch tax purposes, which previously qualified for the Dutch participation exemption. From 1 January 2016, however, the participation exemption no longer appli…