Brazil issues tax regulation program
Provisional Measure 766 has issued and released on 4 January 2017. This provisional measure establishes a tax regulation program for Brazilian taxpayers to settle their tax liabilities. Under this program, taxpayers can resolve their federal tax
See MoreDTA protocol between Brazil and Canada confirm WHT rate on technical services
A Private Ruling 5/2017 (Solução de Consulta 5/2017) has been published in the Official Gazette on 18th January 2016. This ruling confirms that payments made by Brazilian sources to individual or companies resident in Canada for technical
See MoreBrazil issues common reporting standard
Normative Instruction 1,680/2016 has been issued in the official gazette on 29 December 2016 regarding the implementation of the identification of financial accounts. Under the normative instruction, companies are required to submit the e-financeira
See MoreBrazil: Regulation on CbC reporting
Normative Instruction 1,681/2016 was issued in the Official Gazette on 29 December 2016 regarding annual country-by-country (CbC) reporting. According to Normative Instruction 1,681/2016: Legal entities resident in Brazil are obliged to
See MoreBrazil issues changes to tax on services
Complementary Law 157/2016 modifies the Complementary Law 116/2003 and starts new rules for the tax on services and issued in the Official Gazette on 30 December 2016. As stated by the law fundamental changes are- the minimum tax rate increase from
See MoreBrazil: Regulates special payment scheme for tax debts
Normative Instruction 1,677/2016, released in the Official Gazette on 12 December 2016, adjusts the special payment scheme for tax debts become certified to legal entities and the special payment rule was created by Law 155/2016. Law 155/2016
See MoreBrazil: Budget 2017 has been accepted by the president
The Budget for 2017 was accepted by the National Congress on 15 December 2016. According to the budget minimum monthly salary increases from BRL 880 to BRL 945.80 in 2017. The President needs to enact the Budget for
See MoreTIEA between Switzerland and Brazil approved
The tax information exchange agreement (TIEA) between Switzerland and Brazil has been approved by the Swiss parliament on 16 December 2016. The agreement was signed on November 23 2015. This TIEA contains tax-related information on request
See MoreBrazil: Amendments to tax on services
The Senate approved changes to Complementary Law 116/2003 major tax on services on 14 December 2016. The modifications need to be ratifies by the President. The key changes are given below: The tax rate is increased from 0% to 2%; new services (e.g.
See MoreBrazil: 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
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