Brazil's Superior Court of Justice Rules on Taxable Event for Withholding on Outbound Payments

A judgment from Brazil's Superior Court of Justice was published on 13 October 2020 concerning the timing of the taxable event for withholding on outbound payments. The case involved a Brazilian company that made payments under a software distribution contract to a legal entity domiciled abroad. The company made payments under the contract on or before the established due dates (maturity dates) and withheld tax at the time the payments were made. However, the tax authority determined the taxa…