Brazil: Publishes proposed Country-by-Country reporting rules
The Brazilian Federal Revenue Agency on 4 November 2016, published a proposed Normative Instruction to establish country-by-country reporting (CbCR) rules in Brazil for Multinational groups where the ultimate parent company is a resident in Brazil
See MoreBrazil: Updates fictitious credit for CFC rule
Normative Instruction 1,674/2016 released in the official Gazette on 29 November 2016 and in force on the same date of publishing. Normative Instruction 1,674/2016 adjusts the option that, resident companies to submit the profits derived by the
See MoreBrazil: Decision releases concerning the application of the new Brazilian CFC rules
The Federal Court of Curitiba passed on a decision in relation to Process No. 5005596- 52.2015.4.04.7000/PR on May 6, 2016.The single court judgments finish off that a Brazilian taxpayer may remove from the calculation of its corporate income tax
See MoreBrazil: Private ruling published in the Official Gazette on transfer pricing resale price method
Private Ruling 63/2016 published in the Official Gazette of 31 August 2016 clarified that under the transfer pricing resale price method, the fixed profit margins apply according to the economic sector of the legal entity. In the case of resident
See MoreBrazil: New deadlines for corporate tax e-filing
On 3rd December 2015 Brazil’s tax authority (Receita Federal do Brasil - RFB) announced new deadlines for certain information filings by corporate taxpayers for 2015. The guidance of Instruções Normativas nº 1.594/15 and nº 1.595/2015,
See MoreBrazil: Government declares new tax measures
Brazil’s Executive branch has proposed different tax measures that would decrease the expected 30 billion Reais (R$) deficit for 2016 to avoid a budget deficit. Tax incentives Under the proposal, tax incentive for export companies will reduce
See MoreBrazil: Presents new proposal on taxation for financial firms and interest on net equity
Brazilian Senator presented a report on the analysis of Provisional Measure 675 (MP 675) regarding new social contribution on net profits (CSLL) rate and elimination of interest on net equity on 12 August 2015. MP 675: Tax rate (CSLL) increased
See MoreUK ratifies DTAs with Algeria, Brazil, Bulgaria, Croatia, Senegal, and Sweden
The UK has recently released draft legislation to ratify Double Taxation Agreements (DTAs) signed with Algeria, Brazil, Bulgaria, Croatia, Senegal, and
See MoreBrazil issues ruling on withholding tax rate in treaty with France
Brazil has issued confirmation that there is no withholding tax on payments for technical services and technical assistance under the double tax treaty between Brazil and France. Private Letter Ruling 153/2015 on the interpretation and application
See MoreBrazil: Issues new Normative Instruction
The Brazilian Federal Revenue Department issued Normative Instruction (NI) 1568/15 on June 8, 2015. This has restricted the application of the cost adjustments in the calculation of the transfer price based on the Brazilian commodities methods
See MoreBrazil: IMF report assesses fiscal policy
The International Monetary Fund (IMF) has issued a press release following the consultation with Brazil under Article IV of the IMF’s articles of agreement. The report notes that economic growth has decreased in recent years with sluggish
See MoreBrazil: Tax Rules Revised
The Ministry of Finance released Ordinance No. 488/14 reducing the maximum income tax rate for categorization of a tax regime as a privileged tax regime from 20% to 17%. This tax rate was effective from November 2014. Accordance to the Ordinance,
See MoreBrazil & Norway: Protocol to DTA ratified by Norway
The protocol to Income and Capital Tax Treaty (1980) between Brazil and Norway has signed on 20 February 2014 and it has been ratified by Norway. Further details will be reported when they are
See MoreU.S. Chamber of Commerce Strengthens Commitment to U.S.-Brazil Relationship
The United States Chamber of Chamber (USCC)-affiliated Brazil-US Business Council (BUSBC) signed a Cooperation Agreement with the Brazilian National Confederation of Industry (CNI) to conduct studies on a potential trade agreement and report back
See MoreBrazil: Amendments on Controlled Foreign Corporations (CFC) Rules
A deemed tax credit of 9% under CFC rules for Brazilian companies with foreign investment in some predefined industrial sector has been extended by a recent guidance. The deemed tax credit results in the lower taxation of profits earned abroad by
See MoreUS-Brazil: Intergovernmental agreement (IGA) has been signed
Brazil and the United States signed an IGA (intergovernmental agreement) on 23 September 2014 in order to apply FATCA (Foreign Account Tax Compliance Act). The new IGA was focused on the FATCA requirements intended to identify the financial
See MoreBrazil: Reduced income tax rate on manufacturing industries
The Ministry of Finance has declared that, reduced income tax rate from 34% to 25% will impose on foreign income from resident manufacturing industries, on 15 September 2014.This tax benefit already exists for food and construction industries but
See MoreBrazil: Provisional Measure 644/2014 was terminated by National Congress
Brazil was issued Provisional Measure 644/2014 in order to introduce individual income tax legislation for 2015 (tax year) and this Provisional Measure is not converted into law by the National Congress. But recently it was terminated when the
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