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UPDATE STATUS
ABOUT THE AUTHOR
FORMS OF DOING BUSINESS
Main Forms of Doing Business with a Legal Presence
Main Forms of Doing Business
Specific Uses of Available Legal Entities
Group of Companies
Joint Venture
Acquisition of a Target Company and Leverage
Intercompany Financing
Real Estate Development
Family Holding Company and Estate Planning
International Tax Planning and Conduit Structures
Types of Partnerships and Hybrid Entities Available for International Business / Structuring
Advantages and Drawbacks
SA
LTDA
FORMATION
Main Formation Requirements
Incorporation procedures
Registrations
Specific Requirements for Foreign Entities
Tax Consequence of Contributions
The Contributor is a Resident Individual Shareholder
The Contributor is a Resident Corporate Shareholder
The Contributor is a Foreign Person
CORPORATE RESIDENCE
Corporate Tax Residence
Practical Aspects of Tax Residence
Potential Exclusion from Treaty Benefits for Failure to Meet Residence Test
Potential Acquisition of Tax Residence Status by Foreign Entities
Tax Consequences of Acquisition or Loss of Tax Residence
PERMANENT ESTABLISHMENTS
Foreign PE of a Domestic Entity
Domestic PE of a Foreign Entity
Branch-PE
Fixed Place of Business-PE
Agency PE
Commissionaire-PE
PE Force of Attraction Principle
Branch Profit (Deemed) Remittance Tax
PE Risk Grid for Foreign Entities Involved in Business Activities
TAX BASE
Tax Base for Resident Entities
Real Profit Regime
Presumed Profit Regime
Arbitrary Profit Regime
Currency and Tax Compliance Special Regime (Regime Especial de Regularização Cambial e Tributária - RERCT)
Treatment of Foreign Profits / Losses
Tax Consolidation / Group Treatment
Tax Base for Non-Resident Entities
Source Rules with Respect to Income Derived by Non-Residents
Treatment of Internal Dealings and Transfers
Dividends, Interest and Royalties
Services
Other Income
Capital Gains
Qualification of Specific Income Categories for Tax Purposes
Technical Services and Technical Assistance
Software
Interest on Net Equity
DETERMINATION OF TAXABLE INCOME
Main Rules Governing the Determination of Taxable Income
Main Differences between Commercial and Tax Accounting
Depreciation and Amortization
Reserves and Provisions
Deduction of Cross-Border Payments and Non-Deductible Expenses
Excluded and Segregated Income
LOSSES
TAX RATES
Residents
Corporate Income Tax
Other Taxes
Non-Residents
Corporate/Profit Taxes
Withholding Taxes
Exit Strategies
FOREIGN TAX CREDITS
INCENTIVES AND SPECIAL REGIMES
Holding Regimes
Financing Regimes
Intellectual Property Management Regimes
Specific Regimes
Other Regimes
Incentives
BUSINESS TRANSFORMATION AND RE-ORGANIZATION
VAT ON INTERNATIONAL TRANSACTIONS
Import Taxes on the Supply of Goods by Non-Residents
Indirect Taxes on the Provision of Services by Non-Residents
Refund of Indirect Taxes to Non-Residents
BASE PROTECTION AND ANTI-AVOIDANCE MEASURES
GAAR and General Anti-Avoidance Measures
Thin-capitalization and other Restrictions to Interest Deduction
CFC and Similar Regimes
Transfer Pricing
Main Rules
Specific TP Issues
Documentation Requirements
APAs and Dispute Resolution Mechanisms
Other Anti-Avoidance Rules
TAX MANAGEMENT AND COMPLIANCE
Books and Records
Type of Assessment
Calendar of Important Compliance Events
Tax Audits
Audit Process
Statute of Limitations
Interest and Penalties
Interest Compensation for Overpayment of Tax
Appeal Procedures
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