On 15 April 2010, the Federal Court of the 2nd Region (second level of the federal judicial courts) confirmed that Brazil has the right to impose withholding tax on the remuneration for services provided by a company located in France to a Brazilian resident company under the Brazil-France tax treaty.
(a) Background. As is the case with Brazil's treaties with Canada and Germany, the term "profits" is also not defined in the Treaty.
(b…