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of Law 9,430 of 27 December 1996). In addition, the debt must not exceed up to twice the amount ofthe related party’s (creditor) interest in the net worth of the legal entity residing in Brazil (art. 24 of Law12,249 of 11 June 2010).In the case of remittances of interest to a beneficiary that is not a related party, but that is a resident ina tax haven, the interest will only be deductible, on proportional terms, as long as the debt does notexceed 30% of the net worth amount of the corporate entity residing in Brazil (art. 25 of Law12,249/2010).In both cases, the total amount of the aggregate indebtedness of the corporate entity resident inBrazil, cannot be higher than these limits (twice and 30% of the net worth, respectively.Remittances of royalties, or of remuneration for technical support or similar services or the payment oftechnology transfer, are subject to the IRRF, at the rate of 15%, except when there is an internationalagreement to avoid double taxation, providing for a lower rate (art. 710 of the RIR and art. 3 ofProvisional Measure (Medida Provisória - MP) 2,159-70/01). It is important to note that suchremittances are also subject to the levy of the Economic Domain Intervention Contribution (CIDE), atthe rate of 10% (see comments in item 6.1.6.5).Earnings from labor, with or without an employment relationship, and income from the provision ofservices of a personal nature paid, credited, delivered, employed or remitted to persons resident ordomiciled abroad, are subject to the levy of withholding income tax at the rate of 25%, with due regardto the cases of agreements to avoid double taxation (art. 685, II, “a” of the RIR).The income tax rate levied on any amounts that constitute remuneration of invested capital, includingthe remuneration produced by variable income securities, such as interest, bonuses, commissions,premiums, discounts and profit sharing, and positive results received on investments in investmentfunds and clubs, produced by federal government securities, purchased as of 16 February 2006, whenpaid, credited, delivered or remitted to beneficiaries resident or domiciled abroad is reduced to zero,except in countries that do not tax income or that tax it at a maximum rate of under 20% (art. 1 of Law11,312/06).The income tax rate levied on income received on investments in Equity Holding Funds, EquityHolding Quota Investment Funds and Emerging Company Investment Funds when paid, credited,delivered or remitted to individual or institutional beneficiaries resident or domiciled abroad thatconduct financial transactions in the Country in accordance with the rules and conditions establishedby the National Monetary Council (art. 3 of Law 11,312/06) is reduced to zero as well.33