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moreOn December 26, Normative Ruling no 1,773/2017 was published by the Federal Revenue Service of Brazil (RFB), amending Normative Ruling no. 1,037/2010, which lists tax havens* jurisdictions and privileged tax regimes **.
The new legislation updates the list of countries or jurisdiction with favored taxation, removing from the list Costa Rica, Madeira Island and Singapore. On the other hand, their privileged fiscal regimes were added to the corresponding list. This is justified by the fact that these three jurisdictions have made enough changes in their domestic legislation to justify their removal from the list.
The regime of the International Business Center of Madeira (CINM) was added, with reference to Portugal and the Free Trade Zones Regime (RZF) of Costa Rica. Singapore had 20 cases listed as privileged tax regimes added to the list.
RSM is available to assist in any queries about this matter.
(*) Favored taxation is defined as those countries that do not tax income or tax it at a rate lower than 20% or, furthermore, whose domestic legislation does not allow access to information relating to the ownership or ownership of legal entities, as according to article 1, IN 1.037 / 2010.
(**) Privileged tax regime are regimes that: (i) taxes income at a maximum rate of 20%; (ii) taxes the income earned for its territory to a maximum rate of 20%; (iii) grants advantages to non-resident entities without requiring substantive economic activity, or that puts the absence of substantive economic activity as a requirement for the benefit; and (iv) maintain secrecy regarding the corporate structure of legal entities, the ownership of assets or rights or economic operations carried out, as defined in article 24-A sole paragraph, of Law 9,430/96.
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CONTACTS:Marcelo Sampaio |
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