Brazil’s Federal Revenue Service (RFB) has published the Normative Instruction No. 2,265/2025 in the Official Gazette on 13 May 2025, in which it removed the UAE from the list of low-tax jurisdictions and the Austrian holding company regime (for companies without substantial economic activities) from the list of privileged tax regimes.
This decision reflects the UAE’s advancements in fiscal transparency and strategic investments in Brazil. The UAE demonstrated a robust investment plan within Brazil and successfully met the requirements outlined in the updated legislation, which led to its removal from the list of jurisdictions with favourable taxation.
The update is based on Law No. 15,079/2024, which introduced Article 24-C to Law No. 9,430/1996. This new provision enables countries to be removed from the list of jurisdictions with favourable taxation if they actively promote national development through significant investments.
In the case of Austria, the removal of Austria’s tax regime for holding companies without substantial economic activity followed clarifications from the Austrian government. The RFB determined the regime no longer qualifies as privileged and removed it from the list.
These updates demonstrate Brazil’s commitment to aligning its tax laws with international standards while fostering an environment that attracts responsible foreign investment.
