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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.
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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.
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Tax authorities restrict the application of the understanding issued by the STJ in Theme 1,182 and give new contours to the discussion.
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Ordinance changes rules of analysis and makes it more difficult to obtain exemption from issuing of Tax Infraction Notices.
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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.
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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!
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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.
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Carf’ vision and STJ's position in special appeal 1,999,532/RJ.
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STF defines that the fee charged by insurance companies are subject to the incidence of these taxes.
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The STJ's understanding on suspension of protest and registration in Cadin in tax foreclosures guaranteed by performance bond or bank guarantee.
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An analysis of Bill 2,384/23 and ADIs 6,399, 6,403, and 6,415.
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Text approved is the substitute of the rapporteur and will now be submitted to the analysis by the Senate.
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