Treaty detail
United Kingdom - Brazil tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2022-11-29
Effective
2024-01-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 10%
The newly signed UK-Brazil treaty applies a 10 percent rate for qualifying corporate holdings and 15 percent more broadly. As a 2022-era treaty, it reflects post-BEPS standards including a principal-purpose-test approach.
Interest
Rate: 15%
Interest is generally subject to a 15 percent ceiling, with lower rates for qualifying bank and government cases. Brazil traditionally applies higher withholding ceilings than many other UK treaties.
Royalties
Rate: 10%
Royalties are generally subject to a 10 percent ceiling. Trademark royalties may be subject to a separate 15 percent rate, and the article-level definition controls characterization.
Permanent establishment
Construction threshold: more than 9 months
Dependent-agent rules reflect post-BEPS wording. The service PE concept triggers when services are rendered for more than 183 days in any twelve-month period.
Other treaty flags
The new UK-Brazil treaty divides pension rights between source and residence. Government-service pensions generally follow source-country rules. Brazilian domestic-law treatment of foreign pensions still requires separate review.
Seeded article summaries
Article 4
Residence
Defines treaty residence and underpins every other treaty claim.
Residence under the new UK-Brazil treaty reflects contemporary tiebreaker rules and post-BEPS thinking. Dual-residence questions for entities are subject to competent-authority determination in many cases.
Article 5
Permanent Establishment
Defines the source-country business-presence threshold.
Article 5 reflects post-BEPS wording and includes a service PE concept commonly used in Brazilian treaties. The construction threshold applies to projects exceeding nine months.
Article 7
Business Profits
Reserves business profits to the residence state absent a permanent establishment.
Business-profits relief is the practical operating rule for cross-border services and trading between the UK and Brazil. The service PE provisions are particularly relevant for consulting and project work.
Article 10
Dividends
Provides reduced treaty rates for qualifying cross-border dividends.
The new UK-Brazil treaty's dividend article applies a 10 percent rate for qualifying corporate holdings and 15 percent more broadly. Brazil's domestic-law treatment of certain distributions still requires article-level review.
Article 11
Interest
Caps source-country withholding on interest at the treaty rate.
Interest payments under the UK-Brazil treaty are subject to a 15 percent ceiling. Qualifying government and bank cases may benefit from lower rates.
Article 12
Royalties
Caps source-country withholding on royalties at the treaty rate.
Royalties are subject to a 10 percent ceiling under the new treaty, with a separate rate for trademark royalties. The article-level definition governs characterization.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyGB–IE treaty
- TreatyGB–NL treaty
Primary sources
- HMRC Brazil tax treaties pageVerified 2026-05-20
- Brazilian Receita Federal international tax treaties listVerified 2026-05-20
- OECD MLI signatories and partiesVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.