Brazilian Tax Authorities Restates Brazil-Finland Double Tax Treaty
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Brazilian Tax Authorities Restates Brazil-Finland Double Tax Treaty

Recently, Brazilian Tax Authorities issued the Tax Ruling n. 6.017/2019 (“Solução de Consulta DISIT”) restating that technical services and assistance remittances to a beneficiary located in Finland do not trigger Withholding Income Tax (“WHT”). The abovementioned Tax Ruling has binding effect, therefore it must be observed and applied by the Brazilian Federal Revenue in all...

18/06/201918/06/2019by
Brazilian Federal Revenue Service postpones Deadline for the Reporting of Ultimate Beneficial Owner
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Brazilian Federal Revenue Service postpones Deadline for the Reporting of Ultimate Beneficial Owner

The Normative Instruction (NI) of the Brazilian Federal Revenue No. 1.863 was published last December 28th, amending the regulation of the Brazilian National Taxpayers’ Register (CNPJ) and revoking the NI 1.634/2016. The main novelty brought by the new NI is about the recent obligation to indicate the Ultimate Beneficial Owner of national and foreign entities...

07/01/201908/01/2019by
Angel Investor funding and Tax Benefits for Brazilian Investments
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Angel Investor funding and Tax Benefits for Brazilian Investments

Seeking to encourage innovative activities and productive investments, the angel investor concept was introduced into Brazilian law. This type of funding is applied for contributions in companies classified as microenterprise or small business, a legal regime generally adopted by startups in Brazil. Up to that time, investments in innovation companies were performed mainly through convertible...

15/08/201827/08/2018by
The Dispute for Tax on Export of Services
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The Dispute for Tax on Export of Services

Providing services by a Brazilian company to a foreign company should be subject to Tax on Services (ISS) in Brazil? This is a question that may have different answers since the concept of exported services, as defined by Brazilian law, leads taxpayers – and tax authorities – into a gray area. The reason for this...

30/04/201802/05/2018by
Brazilian Tax Aspects on Import of Services
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Brazilian Tax Aspects on Import of Services

Brazilian tax system is very complex as it encompasses several taxes in different levels: Federal, State and Municipal. Additionally, tax authorities also created many ancillary obligations, what brings more complexity to the whole tax system in Brazil. Moreover, the number of taxes also adds costs to certain transactions that, in some cases, gives rise to...

10/03/201810/03/2018by
São Paulo State Creates a New Installment Payment Program to ICMS Debits
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São Paulo State Creates a New Installment Payment Program to ICMS Debits

The Decree nr. 62,709/2017 of São Paulo State creates a new Special Installment Payment Program to ICMS debits (“PEP/ICMS”), related to taxable events occurred before December 31, 2016. The taxpayer must submit the Application to the Installment Payment Program until August 15, 2017 and choose one of the payment methods summarized in the sheet below:...

24/07/201723/10/2017by
Judicial Decision Exempts the Payment of Technical Services Contracted Abroad from Withholding Income Tax
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Judicial Decision Exempts the Payment of Technical Services Contracted Abroad from Withholding Income Tax

In a recent decision, the Regional Federal Court of the 3rd Region (“TRF 3”) decided that the Withholding Income Tax (“IRRF”) must not be charged on international remittances made by a Brazilian company for the payment of technical services provided by a company headquartered abroad. The decision involves a lawsuit filed by a beverage company to...

15/07/201707/10/2018by
Municipality of São Paulo Creates New Installment Payment Program (PPI 2017)
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Municipality of São Paulo Creates New Installment Payment Program (PPI 2017)

The Municipal Law nr. 16,680, published on July 5, 2017, created a new municipal Installment Payment Program (“PPI 2017”), for the payment of tax and non-tax debts, related to taxable events occurred before December 31, 2016. Penalties for traffic violations, contractual obligations, indemnities due to the Municipality’s property damage and residual values from previous installment...

11/07/201715/01/2018by
Rulings order São Paulo State Tax Authorities to analyze Services and Merchandises Circulation Tax (“ICMS”) accumulated credit benefit requests within a reasonable time
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Rulings order São Paulo State Tax Authorities to analyze Services and Merchandises Circulation Tax (“ICMS”) accumulated credit benefit requests within a reasonable time

The São Paulo State Court has been passing sentences favorable to companies headquartered in São Paulo, ordering the São Paulo State Treasury Office (“SEFAZ/SP”) to analyze and issue administrative decisions on Services and Merchandises Circulation Tax (“ICMS”) accumulated credit benefit requests within a reasonable amount of time. In some cases, requests for credit use may...

09/05/201614/01/2018by
New Deadline for Installment Payment of State Debts in São Paulo
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New Deadline for Installment Payment of State Debts in São Paulo

On January 9th, 2016, the Government of the State of São Paulo, enacted Decree n. 61,788/2016 – Special Installment Programme of ICMS (PEP) – and Decree n. 61,789/2016 (Tax debts Installment Programme). Both decrees, essentially, granted additional time for taxpayer currently in debt with the São Paulo tax authorities to pay immediately or enter an...

14/01/201614/01/2018by