Brazil: Changes to Double Taxation Disputes

At the end of November 2018, Brazil introduced a new Normative Ruling on effective dispute resolution processes in order to comply with the OECD`s Action 14 BEPS requirements.

The Normative Ruling NR 1,846/18 replaces NR 1,669/16 which regulates the application of the mutual agreement procedure (MAP) in Brazil’s 33 tax treaties.

Until the change, taxpayers that received a court decision in double taxation disputes were not allowed to use the mutual agreement procedure (MAP). Under the new regulation, the MAP option is open to them.