The Convention has not yet entered into force, which depends on the completion of all legislative requirements set forth by both countries. First, the National Congress of Brazil (both the Federal Senate and the Chamber of Deputies) must approve it as a law, then it must be approved by Brazil’s president and then, finally, it must be published in order to become enforceable.

The Convention’s main benefits will be:

• to provide tax certainty and predictability to business, facilitating long‑term investments;
• to help tackle tax evasion by providing for the exchange of information between countries; and
• to intensify trade and investment, strengthening the Brazil‑UK bilateral relationship.

Below are the main concepts contained in the Convention.

Residence and entitlement to benefits

The Convention has defined the following criteria for an individual to be deemed a resident in both jurisdictions. They will be considered primarily to have residence in the jurisdiction in which: