Finland - Brazil Treaty Development - Details

The IBFD has received the English text of the income tax treaty of 2 April 1996 between Finland and Brazil. Once in force, this treaty will replace the present treaty of 16 February 1972, as modified by the protocol of 12 June 1989. The treaty was concluded in the Finnish, Portuguese and English languages; in the case of divergence of interpretation, the English text prevails. The treaty generally follows the OECD Model Convention.

Dividends paid by a Finnish company to a resident of Brazil are not subject to withholding tax in Finland so long as an individual resident in Finland is entitled to the imputation credit in Finland, which is presently the case. For Brazil, the maximum withholding tax on dividends is 10%. Brazil may also levy a branch profits tax, which may not exceed 10%.