Brazilian IRS reaffirms IoE classification as interest under Brazil–Spain DTT
In brief On March 9, 2026, the Brazilian IRS issued Interpretative Declaratory Act (ADI) # 3, clarifying that interest on net equity (IoE) paid, credited, or remitted by Brazilian companies to partners or shareholders resident in Spain must be classified as interest under Article 11 of the Brazil–Spain Double Tax Treaty (DTT), rather than as […]
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