Mondaq Latin America: Tax
Within the Program "Brasil Maior", Law no. 12,546/2011 created the Social Security Contribution on Gross Income which, until Dec. 31, 2014, and for some economic sectors, will replace the Social Security Contributions provided for in items I and III of article 22 of Law no. 8,2 12/91, calculated, in turn, on the total remuneration paid, due, or credited to ensured employees, autonomous workers, and individual taxpayers.
A summary of the Tax Credit Recovery program of the Federal District.
The Full Bench of the Brazilian Supreme Court recently analyzed the constitutionality of the levy of income tax on profits.
A discussion on Law no. 12,249/2010, which created the fines that correspond to 50% of the value of credits subject of non-ratified Offsetting Statements or undue or non-granted Refund Requests.
On a monthly basis, our firm follows up on the trials held at the Superior Chamber of Tax Appeals of the Administrative Council of Tax Appeals of the Treasury Ministry, the last administrative court for the judgment of the validity/legality of the required federal taxes.
The Federal Official Gazette published on December 24, 2012, SINIEF Adjustment nº 27/2012, which postponed to May 1st, 2013, the beginning of the mandatory presentation of the Import Content Report (Ficha de Conteúdo de Importação - "FCI"), provided for by SINIEF Adjustment 19/2012.
A discussion on the recent changes in the Brazilian transfer pricing rules, introduced by MP 563.
The Full Court of the Federal Supreme Court will start to hear, next Wednesday, the issue concerning the charge or not of the income tax on profits earned by associate companies or subsidiaries abroad.
Provisional Measure nº 563 has been announced to amend the wording of Law nº 9.430 and brought important changes in connection with the transfer price control in Brazil.
Circular of the Central Bank of Brazil no. 3.624 was published on February 6, 2013, establishing the filing term for the Statement of Brazilian Capital Abroad relative to the base dates of December 31, March 31, June 30, and September 30 of each year.
Law no. 12,788, resulting from the conversion of Provisional Measure no. 578, of August 31, 2012, was published on January 15, 2013.
Decree Nr. 7.894, dated January 30, 2013, was published yesterday amending the Regulation of the Tax on Financial Transactions, concerning in particular the Tax on Foreign Exchange Transactions levied upon the inflow of funds in Brazil.
A discussion on the effects of Joint Resolution no. 1 of the Treasury Office and Attorney General Office of the Stte of São Paulo, dated February 28, 2013, came into force, ruling on the necessary administrative proceedings for the settlement of debts of the Tax on the Circulation of Goods and of the Tax on the Circulation of Goods and Provision of Interstate and Intercity Transportation and Communications Services, within the Special Installment Agreement Program.
Law nº 12.546 was published on December 14, 2011, consequent of Provisional Measure nº 540/11, which provided for the applicability of the social security contribution to the companies engaged in the footwear, apparel, leather, Information Technolog, Information and Communications Technology and Call Center areas, and established the Special Regime of Reintegration of Tax Amounts for the Exporting Companies.
The Federal Supreme Court recognized the general repercussion of the discussion involving the levy of the Contribution to the Social Security Funding and the Employees’ Profit Participation Program charged on revenues earned from leases, including real estate owned by the company.
Normative Rule of the Federal Revenue of Brazil ("IN/RFB") no. 1.333, published on January 19, 2013, provides for the filing of the Annual Income Tax Adjustment Return ("DIRPF") referring to the fiscal year of 2013, calendar year of 2012, by individuals that are considered resident in Brazil.
Within the Program "Brasil Maior", Law no. 12,546/2011 created the Social Security Contribution on Gross Income which, until Dec. 31, 2014, and for some economic sectors, will replace the Social Security Contributions provided for in items I and III of article 22 of Law no. 8,212/91, calculated, in turn, on the total remuneration paid, due, or credited to ensured employees, autonomous workers, and individual taxpayers.
The First Section of the Superior Court of Justice has just finished the judgment of the Special Appeal no. 1.322.945/DF and decided favorably to the taxpayers to assure the exclusion of amounts paid by the employers during the holidays and maternity license of social security contributions basis, calculated on the total remuneration paid, due, or credited to ensured employees, autonomous workers and individual taxpayers.
In March 2013, two new income tax treaties signed by Mexico, with Hong Kong and with Qatar, were published in the Mexican Official Gazette.
The Puerto Rico Treasury Department has released regulations to provide guidance on the application of the new rules for controlled groups of corporations and related entities included in the Internal Revenue Code for a New Puerto Rico
Resulta evidente que el tratamiento de las indemnizaciones del derecho civil, tanto en el impuesto al valor agregado como en el impuesto a las ganancias, genera una serie de interrogantes y zonas grises, que se ven reflejados en pronunciamientos administrativos y judiciales, que en más de una ocasión aparecen como confusos y contradictorios.
The general statutory corporate income tax rate for entities incorporated in Argentina including branches or permanent establishments of foreign companies is 35%.
The general statutory corporate income tax rate for Bolivian entities including Bolivian branches of foreign companies is 25%.
A discussion on the recent changes in the Brazilian transfer pricing rules, introduced by MP 563.
Although internationally adopted, the expression "tax haven" has not been used in the Brazilian applicable legislation.
RFB Normative Instruction nº 1.271/2012 was published on May 22, 2012, to amend RFB Normative Instruction nº 1.207/11, and govern the IOF applicability to operations with derivatives.
By means of Decree No. 7894, of January 30, 2013 (Decree 7894/2013), published in the Official Gazette of the Union of January 31, 2013, the Brazilian government decided to reduce from 6% to zero the Tax on Exchange Transactions (Imposto sobre Operações de Crédito, Câmbio e Seguro, ou relativas a Títulos ou Valores Mobiliários - IOF) in the exchange transactions made as from January 31, 2013, for the acquisition of units (quotas) of local Real Estate Investment Funds (Fundos de Investimento Imob
The Brazilian federal tax authorities enacted Regulation No. 1037 ("Instrução Normativa n. 1037/2010") on June 4, 2010 listing jurisdictions classified as tax havens and privileged tax regimes as defined by Brazilian tax legislation.
The Second Chamber of the Brazilian Superior Court of Justice (Superior Tribunal de Justiça – STJ) recently ruled that international conventions signed by Brazil with the government of other countries for the avoidance of double taxation with respect to taxes on income (Tax Treaties) shall prevail over the domestic income tax legislation in the case of a foreign company contracted by a Brazilian company for the provision of services to be performed abroad without transfer of technology .
Brazil has signed tax treaties with the following countries which have not been ratified yet and, therefore, are not currently in force: Paraguay, Russia, Trinidad and Tobago and Venezuela.
The Federal Official Gazette published on December 24, 2012, SINIEF Adjustment nº 27/2012, which postponed to May 1st, 2013, the beginning of the mandatory presentation of the Import Content Report (Ficha de Conteúdo de Importação - "FCI"), provided for by SINIEF Adjustment 19/2012.
Employee Profit Sharing (PLR) is regulated by Law No. 10.101 of December 19, 2000.
For Colombian Tax purposes, the place of incorporation of a company and not the place of its effective management, will determine whether it is resident in Colombia or elsewhere.
As of January 1st, 2008, the general statutory corporate income tax rate is 33%. Unless otherwise provided, all Colombian and foreign entities subject to income tax in Colombia, including Colombian branches of foreign companies are subject to this 33% rate.
As of January 1st, 2008, the general statutory corporate income tax rate is 33%. Unless otherwise provided, all Colombian and foreign entities subject to income tax in Colombia, including Colombian branches of foreign companies are subject to this 33% rate.
Corporate Income Tax. Corporate income tax is levied on companies domiciled in Ecuador.
Mexican resident corporations are subject to a federal corporate income tax at a rate of 30%. The rate will be reduced to 29% in 2013 and to 28% starting 2014.
In March 2013, two new income tax treaties signed by Mexico, with Hong Kong and with Qatar, were published in the Mexican Official Gazette.
The Puerto Rico Treasury Department has released regulations to provide guidance on the application of the new rules for controlled groups of corporations and related entities included in the Internal Revenue Code for a New Puerto Rico
The corporate income tax is the higher of a regular tax ranging between 20% and 39% of net income and an alternative minimum tax of 22 % of "alternative minimum net income". For taxable years ending prior to January 1, 2012 the 39% rate is increased to 40.95%.
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A discussion on the recent changes in the Brazilian transfer pricing rules, introduced by MP 563.
Although internationally adopted, the expression "tax haven" has not been used in the Brazilian applicable legislation.
The Full Bench of the Brazilian Supreme Court recently analyzed the constitutionality of the levy of income tax on profits.
According to Brazilian law, the dividends distributed to the shareholders are exempt from income taxes.
By means of Decree No. 7894, of January 30, 2013 (Decree 7894/2013), published in the Official Gazette of the Union of January 31, 2013, the Brazilian government decided to reduce from 6% to zero the Tax on Exchange Transactions (Imposto sobre Operações de Crédito, Câmbio e Seguro, ou relativas a Títulos ou Valores Mobiliários - IOF) in the exchange transactions made as from January 31, 2013, for the acquisition of units (quotas) of local Real Estate Investment Funds (Fundos de Investimento Imob
In March 2013, two new income tax treaties signed by Mexico, with Hong Kong and with Qatar, were published in the Mexican Official Gazette.
The Brazilian Certificates of Real Estate Receivables (Certificados de Recebíveis Imobiliários – CRI) are securities backed by real estate receivables, which are very similar to mortgage pass-through securities issued in the United States.
The Second Chamber of the Brazilian Superior Court of Justice (Superior Tribunal de Justiça – STJ) recently ruled that international conventions signed by Brazil with the government of other countries for the avoidance of double taxation with respect to taxes on income (Tax Treaties) shall prevail over the domestic income tax legislation in the case of a foreign company contracted by a Brazilian company for the provision of services to be performed abroad without transfer of technology .
Within the Program "Brasil Maior", Law no. 12,546/2011 created the Social Security Contribution on Gross Income which, until Dec. 31, 2014, and for some economic sectors, will replace the Social Security Contributions provided for in items I and III of article 22 of Law no. 8,2 12/91, calculated, in turn, on the total remuneration paid, due, or credited to ensured employees, autonomous workers, and individual taxpayers.
When considering a purchase of a Brazilian company, the first point to call the attention refers to tax succession.
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