On July 1 2019, the Federal Brazilian Tax Authorities (RFB) published Solução de Consulta – Cosit 210/2019 (dated June 24 2019), providing that withholding tax should be levied at a rate of 15% on interest that is accrued but not yet due, where the outstanding debt is used to reduce accounting losses of a Brazilian company via a ‘debit to shareholders account’ transaction.
