The Brazilian tax authorities issued on 20 March 2006 Declaratory Interpretative Act 4 concerning theBrazil-Spain income tax treaty of 14 November 1974 (which serves as an official interpretation issued by the Brazilian tax authorities), setting forth their understanding in connection with payments of dividends, royalties and technical service fees under the treaty.
Following a previous Declaratory Interpretative Act issued on 21 December 2004 and as a result of the application of…