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New Rules for Registration of FDI

The Brazilian Central Bank’s Resolution 4,533/2016 has brought about changes to the registration of foreign investment in Brazil. Now the individual or legal entity registering...

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...