Brazil: Cross-border payments under agreements without technology transfer subject to 10% CIDE (Federal Supreme Court decision)

The Federal Supreme Court upheld the levy of the 10% CIDE tax on remittances from Brazil to foreign beneficiaries.

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November 20, 2025

The Federal Supreme Court in August 2025 upheld the levy of the 10% CIDE (Contribuição de Intervenção no Domínio Econômico) tax on remittances from Brazil to foreign beneficiaries under Law 10,168/2000, confirming its broad application to payments for royalties, technical services, and administrative assistance—even when no technology transfer occurs.

This decision, delivered under the “general repercussion” procedure in Extraordinary Appeal No. 928.943 (Topic 914), applies to all companies and cases involving similar remittances, emphasizing CIDE’s role in supporting science and technology fields.


For more information, contact a KPMG tax professional in Brazil:

Morivan Fernandes | mpfernandes@kpmg.com.br

Fabio Cunha Dower | fabiodower@kpmg.com.br

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