Tax and Customs

RFB’s Private Ruling confirms that most taxes are not payable on commissions to foreign agents

On 10 December 2017, Brazil’s Federal Revenue Department’s (“RFB‘s”) Private Ruling DISIT/SRRF06 6,603/2017 was published addressing the applicable taxes on...

Contracts • Tax and Customs|

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São Paulo to charge Services Tax on SaaS, Online Ads and Streaming Services

On 15 November 2017, the Municipality of São Paulo published Law 16,757/2017. The Law addresses, among other issues, the taxing of software as a service (“SaaS”), the online...

Intellectual Property • Tax and Customs|

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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...

Intellectual Property • Tax and Customs|

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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...

Intellectual Property • Tax and Customs|

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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...

Intellectual Property • Tax and Customs|

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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...

Contracts • Intellectual Property • Tax and Customs|

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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...

Tax and Customs|

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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,...

Corporate • Tax and Customs|

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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...

Tax and Customs|

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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...

Tax and Customs|

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