Brazil issues normative instruction establishing new transfer pricing regulations for 2023
On 24 February 2023, the Brazilian Federal Revenue Office published the Normative Instruction No. 2.132 which establishes the regulation of the taxpayer's choice to apply the new transfer pricing rules according to Provisional Measure (PM) No.
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Brazil issues new transfer pricing legislation to align with OECD transfer pricing guidelines
On 29 December 2022, the outgoing Brazilian President issued draft legislation MP 1.152 to align Brazil’s unique transfer pricing system with the OECD Transfer Pricing Guidelines. The news rule will be compulsory for 2024, for fiscal year 2023,
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Brazil and the UK Begin Negotiations for a Double Tax Agreement
Following the completion of exploratory talks, the UK and Brazil are to hold a first round of negotiations on a double taxation agreement from 12 to 16 September 2022. Brazil began accession discussions with the OECD on 25 January 2022 and has
See MoreBRICS Summit Declaration Notes Progress on Tax and Customs Cooperation
Following the virtual BRICS summit held on 23 June 2022, the Beijing Declaration emphasised the need to cooperate to promote economic recovery. The BRICS group of emerging powers – Brazil, Russia, India, China and South Africa – has
See MoreBrazil: Government proposes new transfer pricing system
On 12 April 2022, the tax authority and Organisation for Economic Co-operation and Development (OECD) met to discuss Brazil’s proposal for a new transfer pricing (TP) system. The Brazilian Economy Minister, Paulo Guedes, said that the creation
See MoreBrazil and OECD present outline of new transfer pricing rules
On 12 April 2022 an event was held to present the outline of the new transfer pricing rules drafted by Brazil following a consultation process with the OECD. After Brazil had expressed the intention to become a full OECD member, Brazil and the
See MoreBrazil: Government allows incentives on most manufactured products
On 25 February 2022, the Federal Government Officially published Decree 10.979/2022, which reduces tax rates by 25% on manufactured products (IPI) such as, freezers, fridges, ovens and washing machines. The decree establishes 18.5% of IPI to be
See MoreBrazil: Government reduces WHT rate on aircraft leasing payments
On 31 December 2021, the Government Officially published Provisional Measure no. 1,094/2021, which reduces the withholding tax (WHT) regarding leasing of aircraft and aircraft engines by airlines engaged in public transportation from 15% to 0% for
See MoreBrazil: STF decides that interest on late tax refunds is non-taxable
On 24 September 2021, the Federal Supreme Court (Supremo Tribunal Federal, STF), ruled Extraordinary Appeal No. 1.063.187) that certain interest that a taxpayer receives on a late tax refund from the treasury should not be included in the
See MoreBrazil: Senate announces to analyze tax reform Bill
On 21 September 2021, the Senate made an announcement that the Senate will analyze tax reform Bill, PL 2.337/2021 , a bill that changes the income tax rules. The Bill represents the second phase of the tax reform, which was approved by the Chamber
See MoreBrazil: Executive Branch sends second phase of draft tax reform to Congress
On 25 June 2021, the Executive Branch sent the second stage of the tax reform proposal to Congress. This Tax reform includes the following changes: Government proposed to reduce the corporate income tax rate from 15% to 12.5% in 2022 and to 10%
See MoreBrazil: Revenue extends the submission deadline of individual tax return
On 12 April 2021, the Federal Revenue Officially published the RFB Normative Instruction 1930/2020, which changed the deadline for reporting the Annual Adjustment Statement of the Individual’s Income Tax Return for 2021 from 30 April 2021 until
See MoreEU: BASIC countries express concern at the proposed Carbon Border Adjustment Mechanism
A Joint Statement issued on 8 April 2021 at the conclusion of the 30th BASIC Ministerial Meeting on Climate Change has expressed concern about the insufficiency and inadequacy of the support provided by developed countries; and is concerned that
See MoreBrazil: Revenue sets thresholds for simplified tax regime in 2021
On 18 November 2020, the Revenue published an Ordinance No. 30 of 18 November 2020, setting the revenue limits for the purpose of paying state tax on the sale of goods, interstate and inter-municipal transportation and communication services (ICMS)
See MoreBrazil: Government submits a Bill to introduce a special tax arbitration process
On 3 September 2020, the Bill No. 4468/2020, was published in Senate to introduce a special tax arbitration procedure. The Bill proposed that during the time of tax audit, this special tax arbitration process would be available to deal with tax
See MoreBrazil: Chamber of Deputies considers new draft Bill regarding digital service tax
On 19 August 2020, a Bill 218/2020, the social contribution on digital services (CSSD), was submitted and considered by the Chamber of Deputies, which provides the introduction of digital service tax (DST). Previously, On 4 May 2020, Mr. João
See MoreOECD and Brazil: Call for Input on Safe Harbours and Simplification Issues
On 30 July 2020 the OECD and Brazil jointly launched a survey looking for comments on the development of safe harbours and other simplification measures. OECD and Brazil The survey is part of a project begun in February 2018 to review the
See MoreBrazil: Bill proposes different COFINS tax regime in COVID-19 pandemic
Recently, the Senate proposed through the Complementary Bill 131/2020 different tax regime for the Contribution to the Financing of Social Security (COFINS) levied on the gross revenue earned by legal entities with high revenue using digital
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