Articles
10Sep 2008
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...
09Sep 2008
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...
21Jan 2008
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...
16Dec 2007
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...
21Oct 2007
For decades, acquisition of rural land by foreigners has been a major issue in Brazil. For over thirty years, rules and regulations have imposed restrictions for foreign ownership of Brazilian land.
At the time the first restrictions were created, the world was under the...
10Oct 2007
In principle, the Sarbanes-Oxley Act of 2002 only applies to American publicly held corporations and to foreign companies that have their papers negotiated in the American Stock Market, as well as their respective directors, officers, in-house and independent auditors. In...
23Sep 2007
Recent data from Brazil’s Federal Revenue Department (FRD) shows that the number of tax audits carried out between January and July 2007 is more than 90 percent greater than for the same period in 2006, and the volume of assessed taxes also has increased by more than 66...