Topics discussed: ICMS Tax War May be Coming to an End; Tax Reform Under Discussion; Reintegra Benefit Reduced to 2% in 2018; Brazil and Japan Sign a Mutual Cooperation Agreement...

As reported in a previous edition, Constitutional Amendment 87 has changed how the State VAT (Tax on the Circulation of Merchandise and Services, or ICMS) is divided in transactions with goods and the performance of transportation services for a final consumer in another state.

The Superior Court of Justice has taken up the decision of Special Appeal #1.221.170/PR, which deals with the definition of inputs for the purposes of Social Integration Program Tax (Programa de Integração Social), or PIS, ...

Brazilian Federal Revenue Office Reviews its Transfer Pricing Guidelines on International Cost-Sharing Agreements

Frise-se, ainda, a conveniência da adoção de safe harbors para os casos de falta de comparáveis, o que consequentemente implica em uma desejável redução de custos de compliance.

The Brazilian transfer pricing rules were introduced into the local legislation by means of Law 9,430, from 1996, coming into force in 1997.

On March 11, 2016, the Brazilian IRS issued Normative Ruling 1,627 to govern the Special Methods of Taxation and Foreign Currency Regularization (RERCT) that was introduced by Law 13,254.

CARF – which is the highest administrative tax court within the framework of the Brazilian Ministry of Finance – has recently issued two opinions with regards to the deferral of the taxation of capital gains ...

Due to the continued state of public emergency in Brazil, the Federal Government has granted several tax breaks to mitigate the economic effects of the COVID-19 pandemic,...

The Federal Revenue Office issued the Private Letter Ruling 95/2018, which has analyzed the transfer pricing calculation through the Resale Price Method by a company that imports steel bars and cut them into pieces for the resale in the domestic market.

After 20 years of negotiations, the European Union and Mercosur have moved forward with the free trade agreement between the two blocs.

O Sucesso na implantação de um programa de integridade e na adoção de práticas de conformidade que buscam reduzir os diversos riscos aos quais se encontram submetidos uma empresa deve ser regido por regras e orientações de conduta próprias.

Brazil recently signedDTCs with Switzerland and Singapore. These DTCs contain several rules aligned with the BEPS Project, such as general anti-avoidance rules and exchange of information among the contracting states' tax authorities.

Provisional Measure 668/2015, published on January 30, 2015, increases the general PIS and COFINS tax rates on imported products, beginning May 1, 2015.

There is an ongoing and significant conflict in Brazil between states and municipalities to decide who has the power to tax transactions involving digital goods, including streaming services and software, especially after the recent approval of ICMS Agreement 106/2017 by the states.

O Superior Tribunal de Justiça ("STJ") retomou o julgamento do Recurso Especial nº 1.221.170/PR, que trata do conceito de insumos para fins de creditamento de PIS/COFINS.

Considerando o regime monofásico do PIS e da Cofins (Lei 10.147/00), é comum que alguns setores — como as indústrias farmacêuticas ou de cosméticos — implementem um planejamento tributário, ...

Following the rules in Supplementary Law 160/2017, the states have approved an agreement (ICMS Convention 190/2017) that establishes rules for validating tax incentives granted improperly...

Seguindo as regras da Lei Complementar nº 160/2017, os Estados aprovaram um acordo (Convênio ICMS nº 190/2017) que fixa as regras para a convalidação de incentivos fiscais...

The STJ recently analyzed an appeal filed by a corporate taxpayer that claimed there was a discrepancy in the case law development regarding application of a late payment fine in cases...