Brazil: 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
See MoreBrazil approves a proposal for re-opening of special regime
The Chamber of Deputies has sanctioned a proposal for the re-opening in 2017 regarding the special regime for regularization of non-notified assets abroad on 15th February 2017. The proposal was approved by the Senate on 23rd November 2016. The
See MoreBrazil publishes rules for filing individual income tax returns
Normative Instruction 1,690/2017 has been released in the Official Gazette on 22 February 2017 and also entered into force at same date. The Normative Instruction 1,690/2017 introduces the rules for filing of individual income tax returns for income
See MoreBrazil: MOF issues new threshold for automatic appeals
The Ministry of Finance (MOF) released a regulation 63/2017 (Portaria 63/2017) in the official journal on 10 February 2017. This has increased the threshold of BRL 2.5 million (previously, BRL 1 million) for automatic complaints (recurso de ofício)
See MoreBrazil published special programme for payment of federal tax debts
Normative Instruction 1,697/2017 published in the Official Gazette on 1 February 2017 regarding special programme for the payment of federal tax and non-tax debts. According to Normative Instruction payment of the debts may be made as follows:
See MoreBrazil publishes capital gains on exchange of shares
Private Ruling 88/2017, released in the Official Gazette on 31 January 2017 regarding the tax treatment of exchange of shares transactions in Brazil. This public ruling imposes on non-resident shareholders. According to the rule, 15% income tax rate
See MoreBrazil: Tax authority defines withholding tax payments for technical services source in US
Brazilian tax authorities define the withholding tax for technical services made available by individuals in United States through Private Ruling 5/2017 (Solução de Consulta 5/2017), published in the Official Gazette on 18 January 2016. The
See MoreBrazil 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
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