On February 19, 2026, Brazil and China commemorate the 33rd anniversary of the entry into force of the agreement to avoid double taxation and prevent tax evasion. The treaty aims to provide greater legal certainty to bilateral operations, protect taxpayers’ rights, and facilitate trade and investment between the two countries.
In April 2025, the parties signed an amending protocol that updates the original agreement in response to the growth of trade and investment flows. The update incorporates international standards promoted by the OECD within the framework of the BEPS project, adjusts the definition of permanent establishment, and introduces a general anti-abuse clause.
The new text also reduces withholding tax rates applicable to dividends, interest, and royalties, including those related to trademarks, to encourage investment and technology transfer. It also strengthens the mutual agreement procedure for dispute resolution, aligning the treaty with current international tax practices.
