Prospects of dividend taxation lead foreign investors to consider options to reduce the impact of this taxation. While the bill’s approval by the Senate remains uncertain, this may be a good time to evaluate safe options avoiding pitfalls Read more
This article explains how tax constraints hinder telecom services in Brazil and addresses reform measures required to attain a more suitable environment for the significant developments expected for the sector in the near future with expansion... Read more
Tax authorities often deny amortization when a vehicle-company is used. But there are grounds to justify its use and case law is not yet settled on this matter. Read more
Obstacles imposed by the Brazilian Business Insolvency Act (Act 11,101/2005) have historically hindered tax-efficient recovery plans and created challenges for insolvent companies to pay their tax debts and for creditors to receive the amounts... Read more
Acquihiring - corporate acquisitions where the primary objective is to hire talents rather than to acquire assets or projects - tends to contribute to change the hiring process in Brazil. Read more
Thomson Reuters Practical Law Read more
Video on Demand expansion in Brazil exposed deficiencies and uncertainties in the domestic taxation of audiovisual services. Understanding this complex issue is important for players willing to remain relevant or to enter the Brazilian audiovisual... Read more
Share-based compensation can be a good incentive to employees and officers. In Brazil, however, companies should pay attention on how to structure SOPs since its characteristics lead to different labor, tax and social security treatments. Until... Read more
Brazil virtually prohibits the payment of royalties for the use of patents and trademarks above 1% of the revenues generated by the manufacture or sale of a product. These idiosyncratic rules make the country less attractive to foreign investments.... Read more
One in four Reals paid in taxes in Brazil come from payroll taxes. While these taxes corresponded to an average 0.4% of GDP in OECD countries in 2016, in Brazil they reached 8.47% of GDP in the same year. Correcting such a key distortion to... Read more
Transferring a Brazilian company to another country is legal but not feasible due to a series of practical obstacles and undesired tax effects. What may be a Government’s hidden intention to keep operations, profits and taxation in Brazil can... Read more
The Brazilian government again intends to change the taxation of investments in certain Brazilian funds, especially FIPs and closed-end funds, effective January 1st, 2019. Similar changes had already been attempted via Provisional Measure No.... Read more
After threatening to charge Withholding Income Tax from local financial institutions acting as legal representatives of foreign investors if any Brazilian residents were identified as ultimate beneficial owners (UBOs) of the foreign investments... Read more
Coluna do Levy & Salomão | JOTA | Janeiro Read more
Valor Econômico | Legislação & Tributos Read more
Changes have been introduced to the taxation of investments on several types of Brazilian funds, including those established as a closed condominium (“Closed Funds”). The matter is dealt with in the Provisional Measure No. 806, from October... Read more
Capital Aberto | Seletas Read more
Mondaq Business Briefing | Latin America Read more
Provisional Measure No. 692/2015 increases the income tax rate on capital gains earned by individuals and certain companies from 15% to 15%-30%. The new rules will become applicable on January 1st, 2016 Read more
Jota (jota.info) Read more
Revista Dialética de Direito Tributário (RDDT) | nº228 Read more
Valor Econômico | Legislação & Tributos Read more
There has been a significant increase of investment in Brazilian companies via Private Equity Funds, created under Brazilian Securities and Exchange Commission Instruction No. 391/2003; the grant of tax benefits to foreign investors investing... Read more
The Municipal Taxpayers Council of the Municipality of São Paulo (last level of administrative jurisdiction for municipal taxes) has recently rendered an important decision unanimously stating that the export of financial advisory services by... Read more
There are several bills pending in the Brazilian Congress aiming to create a wealth tax on "large estates". The two main bills are moving through the House of Representatives under different fast-track procedures. If enacted, the changes may... Read more
The high tax burden on consumption and business activities in Brazil is widely known and criticized for inhibiting business development and economic growth. But while taxation in Brazil harshly impacts on productive activities and the Brazilian... Read more
Arguments against the Levy of CIDE on the Transfer of Funds to Non-Residents Read more
Among the more important changes are limitations on the deductibility of interest paid by corporate entities domiciled in Brazil to related parties located abroad, and particularly to parties located in tax havens. The limits are indexed to... Read more