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Brazil has recently approved a protocol to the double tax treaty between Brazil and Norway of 1980. The original treaty imposed a ten-year limit on the treaty reductions in source-country taxation on dividends, interest, and royalties so that these reliefs expired on 1 January 1992. The protocol extends these reliefs for a three-year period from 1 January of the year following the date on which the protocol enters into force. This date is not yet known as Norway has yet to ratify the protocol. It appears that the reliefs will not apply for the period between 1 January 1992 and the date of entry into force of the protocol.
This article was correct as of 1 April 1997.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
For further information contact Carlos S Romero, Deloitte Touche Tohmatsu, Sao Paulo, Brazil on Tel: +55 11 257 0122, Fax: +55 11 258 8456
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