On 27 June 2019, the Brazilian Federal Revenue Department (“RFB”) published Normative Instruction 1,896/2019. The regulation removes the Republic of San Marino from the list of jurisdictions treated as having favourable taxation and privileged tax regimes (commonly known as “tax havens”).
Jurisdictions are removed from the list when they establish that adhere to international standards of transparency and minimum tax rates.
For the Republic of San Marino, the RFB justified its removal as it is now possible for other countries to obtain tax and corporate information about legal entities registered there (including the chain of ownership and final beneficial owners).
Moreover, the Republic of San Marino has an income tax rate of maximum of 17%, which was regarded as acceptable by the RFB.
The removal from the list makes San Marino more attractive as a jurisdiction as higher withholding income tax rates apply to those jurisdictions that are in the “tax haven” list.
Normative Instruction 1,896/2019 came into force on the same day it was published.
Last modified: July 27, 2019