The Federal Revenue Authorities released Interpretative Normative Instruction (no. 1,474/2014) on 20 June 2014. Certain Swiss tax regimes will be considered ‘privileged tax regimes’ for Brazilian tax purposes.
According to the new rule, regimes that apply to those Swiss administrative companies and resident entities whose tax treatment results in an effective corporate income tax rate and which is less than 20% under federal, cantonal, and municipal legislation.
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