Tax and Customs

Withholding income tax on foreign educational, scientific or cultural services

On 21 November 2017, the Brazilian Federal Revenue Department (Receita Federal do Brasil, “RFB”) published Private Ruling 519/2017 which addresses the charging of...

e-Books: free of ‘impostos’ but not of free of ‘contribuições’

The Brazilian Federal Constitution provides in article 150(VI)(d), that no taxes are to be imposed on books, newspapers, periodicals and paper used for print. This clause aims to...

New State Sales Tax (ICMS) regulations for digital goods

On 5 October 2017, the National Council of Fiscal Policy (Conselho Nacional de Política Fazendária, “CONFAZ”) issued its first regulations on the charging of State Sales...

Analysis of IP Agreements by INPI Made Easier

The Brazilian National Institute of Industrial Property (“INPI”) recently issued new regulations regarding the registration and analysis process for technology transfer...

Mutual Agreement Procedure for DTAs

The Mutual Agreement Procedures (“MAP”) are often found in Double-Taxation Agreements (“DTAs”). MAPs are used as means for settling double-taxation disputes by...

Greater Scrutiny by Customs over Illicit Funds

The Brazilian Federal Revenue Department (Receita Federal do Brasil, “RFB”) Normative Ruling 1,678/2016 (“NR 1,678/2016”) sets out the rules for inspection,...

Tax over Services Extended to More Businesses

Even though the Tax over Services (Imposto sobre Serviços or “ISS”) is a Municipal tax, the Brazilian Federal Government approved, on 30 December 2016, Complementary...

Taxation of Foreign Profits

RFB’s Normative Instruction 1,674/2016 establishes a new option for legal entities headquartered in Brazil to have the profits accrued by their related companies abroad to be...