ARTICLE · 21 FEBRUARY 2016

Law No. 13,254/2016 Regarding The Regularization Of Unreported Funds

Trench Rossi Watanabe Advogados

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In a nutshell, RERCT is applicable to the assets held abroad until December 31, 2014, by Brazilian residents, considering the dollar exchange rate of this date (December 31, 2014).

BrazilTax

Ana Carolina Pinheiro Martins

Lavinia Moraes De Almeida Nogueira Junqueira

Elisabeth Lewandowski Libertuci

Law No. 13,254/2016 was published today establishing the rules of the Special Regime ("RERCT") applicable to the regularization of unreported funds or assets held abroad that were not properly reported to the Brazilian authorities.

In a nutshell, RERCT is applicable to the assets held abroad until December 31, 2014, by Brazilian residents, considering the dollar exchange rate of this date (December 31, 2014). Taxpayers are granted a period of 210 days to start the regularization process, after the regulation of the mentioned Special Regime by the Federal Revenue Service (expected to be published until March 15, 2016).

The regularized assets are subject to tax rate of 15% (income tax) and also subject to a penalty of 100%. Considering the dollar exchange rate of December 31, 2014, and the current exchange rate, the effective tax burden is of 20,05%.

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