Private Ruling 4,020/2018 concerning the exemption under CFC rules for profits acquire by the oil and gas industry was published in the Official Gazette on 19th June 2018. The Decision clarifies that the tax exemption of the profits realized is granted through (direct or indirect) controlled subsidiaries or affiliates in connection with certain activities (eg freight, leasing, rent) and the provision of services related to exploration and exploitation of oil and gas in Brazil, is granted provided the resident shareholder is hired by a legal entity which holds one of the previous agreements.
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