By Decree No. 11,109, of June 29, 2022, the Agreement between Brazil and Singapore to Eliminate Double Taxation on Income and to Prevent Tax Evasion and Avoidance was enacted.
The Treaty follows the standard OECD model, setting the following limits on remittances:
Dividends: 10% or 15%
Interest: 10% or 15%
Royalties: 10% or 15%
Technical Services/Technical Assistance: 10%
There is also a specific provision that restricts the right to benefits granted by the Treaty to qualified persons only, such as holding companies or companies with shares traded on the stock exchange, as a way of restricting the use of the treaty for treaty shopping purposes.
Agreement between the Federative Republic of Brazil and the Republic of Singapore for the Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance
