Brazil 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
See MoreBrazil: Tax authority issues a ruling on tax rates for reinsurers
The tax authority of Brazil has issued COSIT Consultation Response no. 62/2017 (Solução de Consulta n. 62/2017) setting out views of the General Office to Coordinate Taxation (COSIT) on tax rates applicable to reinsurers. The Consultation
See MoreBrazil publishes private ruling on royalty and technical service payments
Brazil has published Private Ruling 316 of 20 June 2017 on royalty and technical service payments and payments for services under cost sharing agreements. The ruling explicates the accountabilities for social security contributions (PIS/COFINS) on
See MoreBrazil: The Federal Government establishes the Special Tax Regularization Program
On 31st May 2017 the Federal Government published Provisional Measure No. 783, which established the Special Tax Regularization Program (PERT). Under the program's rules, taxpayers may settle debts with the Federal Revenue Service and the Attorney
See MoreBrazil: Additional guidance on CbC reporting rules issued
Normative Ruling 1,709/2017 of 25 May 2017 amended the 2016 normative ruling that introduced the country-by-country (CbC) reporting obligation in Brazil effective from fiscal year(FY) 2016. According to the new ruling for FY 2016, the Brazilian tax
See MoreBrazil releases withholding tax guidance on the importation of services
On 22 March 2017, the Brazilian Federal Revenue Service (RFB) released guidance in SC (Solução de Consulta) no. 153/2017 of 2 March 2017 regarding taxes on the importation of services. It primarily applies to the importation of services and the
See MoreBrazilian CFC rules apply despite treaties
The Federal Administrative Council of Tax Appeals (Conselho Administrativo de Recursos Fiscais, CARF) decided on 14 March 2017 that taxation in Brazil of profits of indirect controlled foreign companies (CFCs) under CFC rules is not prevented by tax
See MoreBrazil publishes Normative Instruction 1,700/2017 in the Official Gazette
Decree No 2017-22042 of 7 March 2017 fixing the market interest rates for interest-free liabilities have been published in Official Journal No 15371 on 17 March 2017. The Decree upgrades and replaces Decree no. BLKB2015 / 1650M of 10 December 2015
See MoreBrazil declare targeting plan for tax inspections in 2017
The tax authorities declared the aim plan for tax inspections in 2017 on 2nd March 2017. According to the tax plan focus will be given to following specific topics, taxation of CFC profits tax planning involving company reorganizations and
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