Brazil Tax News
Thin capitalization rules regulated by Federal Revenue Service
Low-tax jurisdictions; Privileged tax regimes – exclusion of 1929 Luxembourg Holding Company Regime from list of privileged tax regimes
Low-tax jurisdictions; Privileged tax regimes – possibility to challenge classification: suspensive effect: Dutch holding companies; Switzerland
Low-tax jurisdictions extended; Privileged tax regimes listed
Treaty between Brazil and France – Brazilian court decision on tax treaty treatment of remuneration of technical services
Transfer pricing rules amended – resale price method
Transfer pricing rules amended
Transfer pricing rules amended
Thin capitalization rules – details
Treaty between Brazil and Peru enters into force
Treaty between Brazil and Peru enters into force
Treaty between Brazil and Peru – details
Treaty between Brazil and Canada, and between Brazil and Germany – Brazilian court decision on tax treaty treatment of remuneration of technical services
Treaty between Russia and Brazil enters into force
New regulation on payments subject to 0% WHT to non-residents
Treaty between Russia and Brazil ratified
Tax ruling clarifies application of CIDE on service fees paid to non-resident related company under CSA
Treaty between Peru and Brazil approved
Treaty between Brazil and Mexico – Brazil recognizes Mexican flat rate business tax as covered under treaty
IOF and CSLL rate increased, PIS and COFINS modified
Treaty between Brazil and Russia approved
Protocol to treaty between Brazil and Belgium – details
Amending protocol to treaty between Belgium and Brazil enters into force
Brazil and Germany signed agreement relating to PIS and COFINS taxes
Treaty between Brazil and Belgium – Brazilian Congress approves amendments to treaty
AG: Most-favoured nation treatment and Community preference do not require extension of the tax sparing credit under tax treaties with Brazil and Greece to third countries
New provisional measure grants PIS and COFINS incentives
Central Bank issues new regulation for foreign investment registration
Dutch Supreme Court decides that Netherlands not obliged to grant credit for Brazilian and Italian withholding tax on interest derived by Belgian PE of Dutch company
Clarification on use of auction prices for transfer pricing purposes
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