TIEAs with the UK and Switzerland in Force

On 30 May 2019, Brazil’s President (Jair Bolsonaro) signed two decrees (Decree 9,815/2019 and Decree 97,814/2019) approving the tax information exchange agreements (“TIEAs”) previously signed by Brazil with the United Kingdom and Switzerland. Both Decrees were published on 31 May 2019 and the TIEAs are now law in Brazil.

The TIEAs cover at least the following Brazilian taxes:

• individual and the corporate income tax (IRPF and IRPJ);
• industrialised products tax (IPI)
• financial transactions tax (IOF);
• rural property tax (ITR);
• contribution for the program of social integration (PIS – for PIS-import, see here);
• social contribution for the financing of social security (COFINS – for COFINS-import, see here); and
• social contribution on net profits (CSLL).

The TIEA with the UK covers at least the following taxes:

• income tax;
• corporation tax;
• capital gains tax;
• inheritance tax;
• value added tax; and
• excise duties.

The TIEA with Switzerland covers at least the following taxes:

• Federal, cantonal and communal income taxes (total amounts of income, accrued income, capital-based income, industrial and commercial profits, capital gains, and other types of income);
• Federal, cantonal and communal capital-based taxes (including property gains tax); and
• Cantonal and communal inheritance and gift tax.

Taxes imposed by States, Municipalities and other subdivisions are only subject to the TIEA “to the extent allowable under the laws” of the country.

The information to be exchanged in very broad and includes information regarding trusts, agents, fiduciaries, nominees and beneficiaries of any legal person.

For more information contact me.

Brazil Brazilian Federal Revenue Department Britain capital gains tax COFINS Contribution for the Program of Social Integration Corporate Income Tax corporation tax CSLL Double Tax Agreements DTA excise duty Financial Transactions Tax Gift Tax Income Tax Industrialised Products Tax inheritance tax IRPJ PIS Social Contribution on Net Profits Switzerland Tax Tax Information Exchange Agreement Tax Treaty TIEA UK United Kingdom value added tax

Last modified: 5 August 2019