Tax Transparency Tag Archive

Tax Appeals Board (CARF) Confirms Tax Payable on Apple Remittances: A Warning for IPR Importers into Brazil

In a landmark ruling that may significantly reshape how foreign tech and content providers operate in Brazil, the Administrative Council of Tax Appeals (Conselho Administrativo de...

Contracts • Intellectual Property • Tax and Customs|

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What is a ‘tax haven’ under Brazilian law?

Brazil has a sophisticated tax system. This makes structuring a transaction to minimise taxes a complicated task. Brazilian tax rules generally treat as “tax favoured or with...

Contracts • Corporate • Intellectual Property • Tax and Customs|

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Brazil’s Transfer Pricing Rules Now Consistent with OECD Guidelines

Brazil's transfer pricing rules are now consistent with the OECD Transfer Pricing Guidelines...

Contracts • Intellectual Property • Tax and Customs|

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Royalties paid for unregistered IP rights now tax deductible in Brazil

Royalties for unregistered intellectual property rights can now be deducted by Brazilian licensees....

Contracts • Intellectual Property • Tax and Customs|

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Brazilian Senate Approves TIEA with Bermuda

Brazil and Bermuda's TIEA has been approved by the Brazilian Senate and should be signed into Law soon....

Tax and Customs|

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Disclosure of Ultimate Beneficiaries to the Brazilian Federal Revenue Department

What needs to be disclosed about the shareholders to the Brazilian tax authorities? Disclosures of UBOs and controllers under Brazilian law....

Corporate • Tax and Customs|

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San Marino removed from Brazil’s tax haven list

On 27 June 2019, the Brazilian Federal Revenue Department (“RFB”) published Normative Instruction 1,896/2019. The regulation removes the Republic of San Marino from the...

Tax and Customs|

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Updated: Brazil-Switzerland Double Tax Agreement Signed

Brazil and Switzerland have entered into a double tax agreement. The Convention for Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax...

Tax and Customs|

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OECD Requests Input on Brazil’s Mutual Agreement Procedures

Quick Read: As part of its Base Erosion and Profit Shifting (“BEPS”) project, the OECD has requested that taxpayers provide input on Brazil’s mutual agreement procedures...

Tax and Customs|

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Brazil-China Customs Agreement in Force

On 30 October 2018, Federal Decree 9,542/2018 was published in the official gazette. The Brazil-China Agreement on Mutual Administrative and Customs Matters was signed by the...

Tax and Customs|

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