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...