Brazil: IRS issued dispute resolution ruling on shared services

26 December, 2013

It has been published that, the latest federal administrative case law and contrasting private rulings issued by different sectors across Brazil on 26 December 2013, the General Coordination of Taxation (COSIT) issued an administrative ruling

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Brazil established new tax accounting rules

09 December, 2013

A provisional measure was published in Brazil on 15 November 2013, to establish new tax accounting rules which rescinds the transitional tax regime method and establishes the new tax rules to align Brazil’s tax accounting rules with the current

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Brazil:Tax authority issues guidance for transfer pricing purposes

04 December, 2013

The Brazilian tax authority has published guidance for determining the pricing of certain exports and imports of goods that are treated as commodities on 6 November 2013.The guidance also presents new probability for price adjustments. Under the new

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Brazil published some special amnesty programs

03 December, 2013

Law 12,865 was published in Brazil’s official bulletin on 10 October 2013 and has now come into force in Brazil. The Law provides for specific rules regarding the expected amnesty programs targeting companies that carry open debts resulting from

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Brazil’s Tax Treatment on shared costs

14 November, 2013

Brazil’s tax authorities published guidance concerning the treatment of social contributions and it related to expenses and cost shared by the taxpayer groups, on 29 October 2013. It is intended to clarify the treatment and apportionment of PIS

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Significant Changes to Brazilian Tax Legislation

14 November, 2013

The Brazilian Ministry of Finance has announced significant changes to the way it will tax profits sourced from abroad, on 18 October 2013. The stated aim is to increase the competitiveness of Brazil as a business location and bring it into line

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Protocol to treaty between Brazil and India signed

04 November, 2013

Brazil and India signed an amending protocol to the Brazil – India Income Tax Treaty (1988), in Brasilia on 15 October 2013. Currently no further details of the protocol are

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Brazil: Procedure to file requests for tax consultations

22 October, 2013

Brazil issued Normative Instruction 1,396/2013 on 30 September 2013.This Instruction regulates the administrative procedure to consult the federal tax authority on the interpretation of the tax and customs legislation concerning taxes administered

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Brazil: Tax authority has issued ruling on tax treatment

22 October, 2013

The Federal Tax Authority issued Ruling No. 58/2013 on 27 August 2013, published in the Official Gazette on 30 August 2013, concerning the tax treatment of amounts deposited into escrow accounts associated with specific conditioned

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Brazil: Tax Authority has published guidance on Transitory Tax Regime

22 October, 2013

Tax Authority has published guidance on the Transitory Tax Regime in the Official Gazette on 17 September 2013, introduced the Federal Law 11,941/2009. One of the main motives of Law 11,941/2009 was to make the Brazilian GAAP more adaptable with the

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Brazil: Daimler to Build New Factory

22 October, 2013

It has been published that, German auto-maker Daimler AG said early in October that it plans to set up a new Mercedes-Benz assembly plant in Brazil on 7 October 2013. One of the aims of this move is to reduce the impact of Brazil’s country’s

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Brazil: Changes to transfer pricing regulations

22 October, 2013

Brazil issued Normative Instruction 1,395/2013 on 30 September 2013.This Instruction introduced changes to Normative Instruction 1,312/2012 regarding the prices that must be used in cross-border transactions involving the sale and purchase of goods,

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Brazil: Tax Earnings Up on Income Tax Collection

06 October, 2013

Brazil’s tax administration, the country’s federal tax revenue rose 2.68% year-on-year to BRL 83.2bn in August 2013, has released on 26 September 2013. The statistics show that from January to August the government collected BRL722.2bn in tax

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Brazil: Determination of capital gains for non-residents

19 September, 2013

The Resolution Ruling COSIT 16/2013 was issued by the Federal Revenue Office on 9 September 2013 and published in the Official Gazette. The ruling confirmed that capital gains obtained by non-residents must be determined according to the regulations

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Brazil: Guidance Issued on the Pricing of Interest Bearing Transactions

01 September, 2013

The Brazilian Ministry of Finance has issued an ordinance 427/2013, On 2 August 2013, which finally define and clarifies the interest rate spread and that was mentioned but not specified in Law 12.766/2012. Under Ordinance 427/2013 where the

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Brazil terminates Provisional Measure 612/2013

27 August, 2013

The measure to extend the presumed profit regime and make other relevant changes to the Brazilian tax law has been revoked. Provisional Measure 612/2013 was not converted into law by the National Congress within the extended 120 calendar-day period

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Brazil: Increase in revenue limit to opt for presumed profit method

02 June, 2013

The government of Brazil has again increased the gross income limit for companies to opt for taxation under the presumed profit regime.  Companies electing to use the presumed profit method are taxed on a statutory rate applied to their gross

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Brazil: Expands Threshold for Companies for presumed Profit Method

16 May, 2013

The profit method is one of four calculation regimes that may be applied by some companies for the computation of profits for Brazil’s corporate income tax. This is a simplified regime that enables a company to pay tax based on a percentage of its

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