The Executive Branch has published Decree No. 12,667, which enacts the Protocol amending the Double Taxation Agreement between Brazil and India, with effects on taxable events starting in January 2026.
The new Protocol represents an important step toward the modernization of Brazil’s international tax policy, promoting greater legal certainty and alignment with OECD best practices.
The amendments directly affect the taxation rules on:
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Dividends
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Interest
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Royalties
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Technical services
In addition, the Protocol introduces Limitation on Benefits (LoB) provisions, designed to prevent treaty abuse and ensure that benefits are granted only to taxpayers meeting the required economic substance and effective tax residence criteria.
These changes aim to strengthen tax transparency and prevent tax avoidance and evasion practices, bringing Brazil closer to international standards of tax cooperation.
Our team has reviewed the Decree in full and prepared an exclusive One Page summarizing the main changes and new rates applicable under the Brazil–India Double Taxation Agreement.
📲 Click here to access the full material.
