Withholding Tax (IRRF) on the Remittances of Royalties and Dividends from Brazil to Beneficiaries in South Korea


Withholding Tax (IRRF) on the Remittances of Royalties and Dividends from Brazil to Beneficiaries in South Korea


The Interpretative Declaratory Act SRF (Federal Revenue and Customs Administration) nº 3, from 17th March 2006, made changes concerning the rate of Withholding Tax on remittances of Royalties and Dividends from Brazil to Companies or Permanent Establishments in South Korea. According to said Act, the maximum rate of Withholding Tax on royalties (not being applicable in cases of license or concession of industrial or commercial trademark use, in which the rate remains as 15%), as well as of any income from technical assistance services and from technical services, shall be of ten per cent. Considering Withholding Tax on dividends remittance, the Act states that the applicable rate shall be of ten per cent, except in the situations that a more favorable treatment in the domestic law is enforceable. These rules are in force since January 2006.