The new obligation to identify the equity interest chain until it reaches the final beneficiary has its initial term extended to July 1st, 2017
On May 9, 2016, the Brazilian Federal Revenue has published the Normative Instruction No. 1,634/2016, which established, among other innovations, the obligation to identify, in the National Register of Legal Entities (CNPJ), the equity interest chain of a legal entity and of certain other specific entities until it reaches the final beneficiary of said entities, understood as the natural person who, in the last instance, directly or indirectly owns, controls or significantly influences the entity or the natural person on whose behalf a transaction is conducted. With this new fiscal obligation, it is intended to prevent corporate anonymity and to face corruption, money laundering, tax evasion, terrorism, drug and human trafficking, among other illegal acts.
The term, which originally began on January 1st, 2017, was extended to July 1st, 2017, pursuant to Normative Instruction No. 1,684 of the Brazilian Federal Revenue, both for entities which request its register as of this date and for entities already registered before this date. In the latter case, it is necessary to promote the updating of the data only when a cadastral change is made as from July 1st, 2017, observing the final term of December 31st, 2018, which was maintained in all cases.
The Corporate Team of Azevedo Sette Advogados is available for any clarification, as well as to assist in the procedures for adaptation to the new system.