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Referencing: https://websharks.zendesk.com/agent/tickets/4610
This is the response of PayPal:
"Regarding your question, I noticed that you didn't specify any currency in your SetExpressCheckout. > When you don't specify any currency, it will be defaulted to USD. That explains why when you try to pay using Brazilian Account you will received those error because Brazilian Account can only pay Brazilian Merchant in Brazilian Real."
It would seem this is a change in the PayPal API, where even with a $0 amount in a billing agreement request, there now needs to be a currency code associated with the $0 amount? I'm going to submit a test file for customer experimentation.