Brazil: Tax exemption to encourage Initial Public Offerings
On June 16 of 2014 the Ministry of Finance confirmed that the initial public offerings (IPOs) of smaller company’s investment will be cut from the capital gain tax by 15% and the capital gains tax will not have an effect on infrastructure
See MoreBrazil: Tax exemption from Foreign Loans
The Finance Minister of Brazil declared that the government has announced to cut some tax on foreign loans and from the Tax on Financial Transactions (IOF) on 4 June of 2014 and introduced a new Decree No. 8263The 6% IOF will no longer applicable
See MoreBrazil: Superior Court Rules in Vale CFC Appeal
The Superior Court of Justice in Brazil has arrived at a decision in relation to the mining company Vale. The Court has ruled that profits of Controlled Foreign Companies (CFCs) of Vale in Belgium, Luxembourg, and Denmark would not give rise to a
See MoreBrazil – Tax Hike on Drinks Postponed
Brazil is delaying until September 2014 a proposed rise in indirect tax on certain types of drink. The original proposal was that the tax on energy drinks, beer and some fruit juice would increase by around 1.5 percent on average from 1 June 2014.
See MoreBrazil- Taxes on Drinks Ahead Of World Cup Increases
To take full benefit from the large number of visitors to the country this year, Brazil is to increase taxes on certain categories of drink such as beer, energy drinks and some fruit juice before the beginning of the soccer World Cup which is to be
See MoreBrazil and Norway Sign Protocol to DTA
Brazil and Norway signed a Protocol to their double tax agreement on February 20, 2014. No further details are currently
See MoreBrazil – Tax authority revises position on cross-border reimbursement arrangements
Brazil’s tax authority has issued a ruling to a taxpayer reflecting a change of position concerning cross-border cost reimbursement arrangements. Traditionally, the tax authority (Receita Federal do Brazil—RFB) has imposed a high tax burden of
See MoreBrazil – Ruling permits taxpayers to align their transfer pricing policies
According to a recent ruling by the Brazilian tax authority taxpayers should be able to better align their transfer pricing policies to eliminate potential contingent liabilities, reduce taxable adjustments, and/or eliminate the double taxation
See MoreBrazil – Social Security Tax on Exports to Trading Companies
The tax department has issued guidance clarifying that revenues from the sale of products to trading companies for the purpose of export are subject to social security taxation. Normative Instruction 1436 (IN 1436) released on 9 January 2014 was
See MoreBrazil: Withholding tax thresholds for Employee Profit-Sharing Plans Increased
The employee profit-sharing plan (participação nos lucros ou resultados, PLR) related tax withholding thresholds in Brazil have recently been modified. This will be applicable from 1 January 2014. For the taxable year 2014, the tax withholding
See MoreBrazil Repeals Transitional Tax Regime and established important changes to tax system
Brazil’s Federal Government has published Provisional Measure No. 627 (PM 627) on 12 November 2013, containing a long expected set of rules that not only repeal the Transitional Tax Regime(TTR) but also added new rules aimed at permanently
See MoreTrilateral Cooperation on Fiscal Transparency among United States, Brazil and El Salvador
Focusing on improve tax collection, effective and efficiency of fiscal transparency, an International Initiative for Trilateral Cooperation has been announced by the Governments of El Salvador, Brazil and the United States on December 2, 2013. These
See MoreBrazil: IRS issued dispute resolution ruling on shared services
It has been published that, the latest federal administrative case law and contrasting private rulings issued by different sectors across Brazil on 26 December 2013, the General Coordination of Taxation (COSIT) issued an administrative ruling
See MoreBrazil established new tax accounting rules
A provisional measure was published in Brazil on 15 November 2013, to establish new tax accounting rules which rescinds the transitional tax regime method and establishes the new tax rules to align Brazil’s tax accounting rules with the current
See MoreBrazil:Tax authority issues guidance for transfer pricing purposes
The Brazilian tax authority has published guidance for determining the pricing of certain exports and imports of goods that are treated as commodities on 6 November 2013.The guidance also presents new probability for price adjustments. Under the new
See MoreBrazil published some special amnesty programs
Law 12,865 was published in Brazil’s official bulletin on 10 October 2013 and has now come into force in Brazil. The Law provides for specific rules regarding the expected amnesty programs targeting companies that carry open debts resulting from
See MoreBrazil’s Tax Treatment on shared costs
Brazil’s tax authorities published guidance concerning the treatment of social contributions and it related to expenses and cost shared by the taxpayer groups, on 29 October 2013. It is intended to clarify the treatment and apportionment of PIS
See MoreSignificant Changes to Brazilian Tax Legislation
The Brazilian Ministry of Finance has announced significant changes to the way it will tax profits sourced from abroad, on 18 October 2013. The stated aim is to increase the competitiveness of Brazil as a business location and bring it into line
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