Brazil Tax News
Protocol to treaty between Brazil and India signed
Federal Revenue Office Private Ruling – CFC rules compatible with tax treaties
Normative Instruction 1,391/2013 – Changes to obligation to provide information on cross-border transactions between residents and non-residents
Spin-off does not trigger Brazilian CFC rules prior to 2001 when investment in foreign entity is transferred as part of transaction
Administrative Tax Appeals Council rules on taxable capital gains on exchange of shares
Treaty between Argentina and Brazil – Argentine Court of Appeals rules on the application of transfer pricing method
Law 12,814/2913 increased gross revenue limit for opting to presumed profit regime
Provisional Measure 582/2012 converted into law
Provisional Measure 612/2013 – presumed profits regime extended and other relevant changes
Supreme Federal Court issues decision on profits derived by foreign controlled and affiliated companies for corporate income tax purposes
Filing procedures for transactions involving non-resident persons – Regulations amended
Senate approves provisional measure to extend presumed profit regime
Treaty between Brazil and Turkey enters into force
Tax benefits amended by Provisional Measure 601/2012
New transfer pricing provisions – regulations
Transfer pricing provisions – amendments to interest payments regulations
Transfer pricing regulations on interest payments – amended
Differentiated and special tax monitoring rules – new criteria for corporate taxpayers in 2013
Accelerated depreciation for listed items – regulated
Federal Revenue Service confirms application of transfer pricing rules to back-to-back transactions
Requirements for cost-sharing agreements
Provisional Measure 582/2012
Provisional Measure 563/2012 – converted into law
Provisional Measure 578/2012 – Accelerated depreciation of motor vehicles for transport of goods and listed wagons, locomotives and loco tractors
Treaty between Brazil and Trinidad and Tobago – details
"Internal goodwill" amortization is possible according to the Administrative Court
Treaty between Brazil and Turkey – details
New filing procedures for transactions involving non-resident persons
Superior Court of Justice decision on treaty treatment of remuneration of services
Treaty between Brazil and Venezuela enters into force
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