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Brazil Ruling that Interest on Equity Capital Received by Holding Companies subject to PIS/COFINS

|Approved Changes|Brazil
Brazil

The Brazilian tax authorities recently issued Ruling 84/2016, which includes that the contributions for the Program for Social Integration Contribution (PIS) and Contribution for the Financing of Social Security (COFINS) apply for interest on equity capital (JCP) received by holding companies under the cumulative regime. In the ruling, the authorities based their position on the change in the concept of gross revenue, which forms the contribution base for PIS/COFINS. In 2014, the concept was …

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