Brazil: RFB clarifies Transfer pricing rules on import of products
On 30 august 2018, the Department of Federal Revenue of Brazil (RFB) published a ‘Private Ruling 95/2018’ in the Official Gazette which clarifies the calculation of price parameter on import of steel product for resale. Under this Private Ruling
See MoreBrazil modifies fines applicable for companies under special regime and exempt entities
Normative Instruction 1,821/2018, published in the Official Gazette of 31 July 2018, modifies the fines applicable to companies taxed under the presumed or determined profit regime and exempt entities as follows: 5% of the gross income in case
See MoreBrazil: Mixed commission approves Provisional Measure 836/2018
The mixed commission of the Senate and Chamber of Deputies approved the conversion into law of Provisional Measure 836/2018 on 14 August 2018, which will effects from 1st September 2018. The measure still needs to be approved by the plenary of both
See MoreBrazil clarifies CFC rule regarding exemption for oil and natural gas industry
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
See MoreBrazil: Government sanctioned guidance regarding new tax incentives for automotive sector
On 5th July 2018 government sanctioned guidance (Provisional Measure 843/18 (PM 843)) that initiates a new tax incentive program for the automotive sector. According to the program the following main tax incentives for a five-year period, which may
See MoreBrazil: Maximum tax refund reduces for exporting companies
Brazil has published Decree No. 9.393 of 30th May 2018 in the Official Gazette, which amends Decree No. 8,415, of February 27, 2015, which regulates the application of the special regime for the Reintegration of tax values for exporting
See MoreBrazilian government adopted several measures regarding incentive in certain sectors
Brazil has published Law 13.670 of 30 May 2018, which was enacted to reduce the number of activities of companies that may continue calculating the social security contributions upon gross revenues of services and/or products. The law includes a
See MoreBrazil changes R&D tax incentives
Brazil released the National Congress Act No. 8 of 14 March 2018 in the Official Journal. The Act extends by 60 Days of Provisional Measure No. 810 of 8 December 2017. This act changes the tax incentive for IT companies investing in research and
See MoreBrazil releases Private Ruling regarding deduction of payments for certain Intra-group services
Brazil has recently released Private Ruling 1001 of 9 January 2018 regarding the deduction of certain cross-border payments to a foreign subsidiary, including strategic decision support, information management, risk management and management of the
See MoreOECD: Project to examine differences between Brazil’s transfer pricing rules and the Guidelines
On 28 February 2018 the OECD and Brazil began a joint project to examine the similarities and gaps in approaches to valuation of cross-border transactions. The project aims to produce an assessment of possibilities to bring the transfer pricing
See MoreBrazil publishes provisional measure on special tax regime
Brazil's provisional measure 795/2017 was turned into Law 13.586 / 2017, as published in the Official Journal of 29th December 2017. Provisional Measure 795/2017, initially released on 18th August 2017, provides for the tax treatment of exploration
See MoreBrazil: Government changes tax rules on the oil and gas tax industry
Brazil has published the National Congress Act 53 of 10th October 2017 in the Official Gazette for extending the Provisional Measure (PM) 795/2017 of 18th August 2017. Provisional Measure (PM) 795/2017 provided for the tax treatment of oil
See MoreBrazil: Provisional Measure publishes in the official gazette regarding revised CFC rules
On 18th August 2017, Brazil published Provisional Measure No. 795 ("MP No. 795/2017") in the official gazette 2017 regarding revised CFC rules for Brazilian organization. Provisional Measure No. 795/2017 which provides for changes in the tax
See MoreBrazil announces a strategy to simplify tax complex control system
Brazil’s Inland Revenue provided four fiscal simplification measures aimed at reducing costs for businesses and enhancing the business environment of the country on 7th August 2017 at a meeting and those are given below: Improving the
See MoreProtocol to treaty between Argentina and Brazil signed
Argentina and Brazil signed an amending protocol to the, Argentina - Brazil Income Tax Treaty of 1980 on 21st July 2017. The protocol sets out maximum levels of taxation at source in specific categories of income; modifies the method to avoid
See MoreBrazil publishes amended regulation on CbC reporting
Normative Instruction 1,722/2017 published in Brazil’s Official Gazette on 17th July 2017 amends Normative Instruction 1,681/2016 relating to guidance on CbC reporting. According to NI 1,722/2017, transitional provisions apply if a legal entity
See MoreU.S. and Brazil sign an agreement on the exchange of country-by-country reports
According to an IRS announcement on its website, the competent authorities of U.S. and the Brazil have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of
See MoreBrazil launches consultation on proposals for new customs procedures
Brazil has recently inaugurated a consultation on proposals for new customs action plans. On a new website the tax authority plans to integrate all processing and data for its foreign trade operations and make the export process easier. Responses to
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