Tax
Brazilian legislation on the taxation of investments abroad will undergo major changes if Bill 4.173/23 is approved in its entirety. These changes could impact the way Brazilian investors and companies operate and invest in assets outside the country.
Legal framework for guarantees, which changes the rules for taxing non-resident investments, is approved by the House of Representatives and goes to presidential sanction.
Tax authorities restrict the application of the understanding issued by the STJ in Theme 1,182 and give new contours to the discussion.
Ordinance changes rules of analysis and makes it more difficult to obtain exemption from issuing of Tax Infraction Notices.
Approved by the Senate, a bill of law that regulates the subject will be voted on by the House of Representatives. Legislative amendments aim to maintain the non-cumulativeness method and the enjoyment of tax benefits.
We have prepared this e-book with insights from our partners on the main impacts of applying the new rules, the transactions covered within their scope, and the contentious issues. Take a look!
The Federal Government have announced the postponement, but are yet to release the new date of the obligation, which should coincide with the replacement of GFIP by DCTFWeb.
Carf’ vision and STJ's position in special appeal 1,999,532/RJ.
STF defines that the fee charged by insurance companies are subject to the incidence of these taxes.
The STJ's understanding on suspension of protest and registration in Cadin in tax foreclosures guaranteed by performance bond or bank guarantee.
An analysis of Bill 2,384/23 and ADIs 6,399, 6,403, and 6,415.
Text approved is the substitute of the rapporteur and will now be submitted to the analysis by the Senate.