News & Recent Work

Articles

Brazil's Corporate Taxpayers Must Elect Tax Calculation Method for 2009

Brazilian corporate taxpayers have until either January 31 or February 27 to elect their income tax calculation method for fiscal 2009. There are three options available (subject to specific limitations): the actual income tax regime (lucro real); the presumed income...

Professional Service Providers Subject to Social Tax, Brazil's Supreme Court Rules

Professional service providers suffered a major tax defeat on September 17, when Brazil’s Supreme Court (STF) ruled that they are subject to the 3 percent COFINS (Contribution for the Financing of Social Security). The ruling is more important than a similar decision...

Brazil Considering VAT on Mineral Exports

Brazil’s House of Representatives is reviewing two bills that propose to tax exports of minerals in natura with the state value added tax (ICMS). Rates would be progressive over a 10-year period after the bills enter into law. Constitutional Amendment Project 283/2008...

Brazil's Revenue Department Clarifies Tax Treatment of Cost-Sharing Arrangements

Brazil’s Federal Revenue Department (FRD), in a recent private letter ruling (PLR), has clarified the tax treatment of cost-sharing arrangements between a Brazilian company and its foreign parent company for transfer pricing and tax purposes. For both income tax and...

Brazil's Superior Court Allows Deduction of Excess VAT Credits

In an unprecedented decision, Brazil’s Superior Court of Justice (STJ) has ruled that an exporter may deduct as costs the accumulated tax credits of state value added tax (ICMS) if, because of its exempt export activities, the company cannot recover or use the credits...

Brazil Expands Definition of Low-Tax Jurisdiction

...

Brazil Creates Return to Report Taxpayers' Financial Information

As anticipated, Brazil’s Federal Revenue Department has created a new tax return to report taxpayers’ financial transactions. The new tax return was created by Normative Instruction 802/2007, published in Brazil’s official gazette of December 28, the last...

Brazil Using Compliance Measure Against Attorneys With Foreign Clients

After Brazil’s judiciary signed a cooperation agreement with the Central Bank a few years ago, judges gained a powerful instrument that enables them to freeze bank account funds online. Unfortunately, that power has become a dangerous instrument for attorneys that...
prev next