INTERPRETATIVE DECLARATORY ACT SRF Nº 3 OF 17 MARCH 2006 (Unofficial translation)

The FEDERAL REVENUE SECRETARY, using the attributions conferred upon him by paragraph 3 of Article 230 of the Federal Revenue Secretariat’s internal regulations, approved by the Minister of Finance’s Ordinance nº 30 of 25 February 2005, and having regard to the provisions of items 3 and 4 of the Protocol to the Convention between the Federative Republic of Brazil and the Republic of Korea for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, promulgated by Decree nº 354 of 2 December 1991, to paragraphs 1 and 6 of Article 10 of the Agreement between the Federative Republic of Brazil and the Republic of Finland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, promulgated by Decree nº 2,465 of 19 January 1998, and to letter b of paragraph 2 of Article 12 of the Convention between the Federative Republic of Brazil and the State of Israel for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, promulgated by Decree nº 5,576 of 8 November 2005, declares:

Article 1. In respect of dividends and profits dealt with, respectively, in paragraphs 2 and 5 of Article 10 of the Brazil-Korea Convention, of royalties dealt with in letter b of paragraph 2 of Article 12  of the aforementioned Convention, and of any income derived from the rendering of technical assistance and technical services dealt with in item 4 of the Convention’s Protocol, subject to the provisions of a more beneficial domestic law, the income tax withheld at source cannot exceed 10% of the gross amount of the values in question, where the beneficial owner is a resident of Korea.

Article 2. This Interpretative Declaratory Act shall take effect as from 1 January 2006.

JORGE ANTONIO DEHER RACHID