Publications | Tax
The right to a tax offset recommends reflection on the rules issued by the legislator that shape such offsets. Among the rules, special mention should be made of section 170-A of the National Tax Code (CTN), introduced by Complementary Law No. 104/2001 (LC 104/01).
Although it is part of the Base Erosion and Profit Shifting (BEPS) Project to counteract multinationals’ tax planning that uses the loopholes of the international system to reduce their overall tax burden, Brazil has not signed the Multilateral Instrument (MLI) to implement the changes suggested in bilateral treaties to avoid the double taxation (double tax treaties) in the form of a single negotiation.
Last year was special for the Administrative Council of Tax Appeals (Carf). The period began with heated discussions (and many lawsuits) questioning the productivity bonus of tax auditors and ended with the joining of the representatives of the Brazilian Treasury in the strike for regulation of the bonus.
This article discusses the possibility that taxpayers may obtain from the Public Treasury reimbursement of expenses incurred in contracting for a bank guarantee or insurance-guarantee offered in guarantee in tax executions as a requirement for filing a motion to stay the execution.
Since the Federal Police launched Operation Zelotes in 2015, which unveiled corruption cases in the Administrative Tax Appeals Board (CARF), the body has undergone several institutional changes, such as a change in its directors, changes in internal rules, reduction in number of panels, among other measures that sought to reformulate the body's procedure for deciding cases.
Learn about ADENE and the tax benefits it offers, their costs, and the time limitations for businesses.
Aiming at counteracting tax planning used by multinationals that take advantage of the heterogeneity of the international system to reduce their overall global tax burden, the Organization for Economic Co-operation and Development (OECD) and the Group of 20 (the so-called G-20, which includes the 19 largest economies in the world and the European Union) started in 2013 the Base Erosion and Profit Shifting (BEPS) Project.
A virtual financial asset very much in vogue, bitcoin is a bet by economists to cheapen transactions, especially those that occur in the international sphere.
Covenant No. 52/2017, recently issued by Confaz (National Finance Policy Council), followed the understanding of the Second Panel of the STJ (Superior Court of Justice) in the sense that the ICMS due under the withholding regime (ICMS-ST) is embedded in its own calculation basis.
Decree No. 9,042, promulgated by the President of Brazil in early May, modified the rules for determining the reference price of oil and the basis for calculating royalties and special participations by adding provisions to Decree No. 2,705/1998.
Bitcoins have gained increasing prominence in the media. In March, the price of each unit surpassed the value of one ounce of gold for the first time. In addition, some online retailers have begun to accept bitcoin as a means of payment, which has also put the virtual currency in the media. Despite this growing popularity, however, bitcoin is still a mystery to many.
A specific point of the Special Tax Regularization Program (PERT), instituted by Provisional Presidential Decree No. 783, of May 31, 2017 ("MP"), has been questioned by some companies and will in many cases be essential in reaching a decision on whether to join the program. It is a reduction of the initiation fee from 20% to 7.5% offered in some situations.
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