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Economic literature is unanimous in stating that several factors influence the flow of direct investments and immigration.1 These include tax policies, infrastructure, local markets, labor opportunities, and, mainly, the quality of life. In a moment that the United States, the largest economy in the world, is supposed to implement a Copernican[...]

Moving forward with the process of adapting Brazilian legislation to the Global Anti-Base Erosion Rules, the government published Provisional Measure No. 1.262/2024, converted into Law No. 15.079 in December 2024, which partially adopted the OECD Pillar 2 rules. The new rules aim to establish a minimum effective tax rate of 15% for large[...]

The Brazilian Federal Government sent to Congress, on June 25th 2021, a tax reform proposal focusing on income tax. The proposed bill (PL 2.337/2021) brings relevant changes related to Corporate Income Tax. Afterwards, on September 2nd 2021, the bill was approved, with amendments, by the Chamber of Deputies, and is still subject to approval by[...]

The Brazilian National Congress approved on September 2 the preliminary text of the income tax reform (bill 2,337), which includes important changes from the original draft presented June 25. According to the approved text, the corporate income tax (IRPJ) rate will be reduced from 15% to 8%, after the implementation of an additional[...]

The Brazilian government presented on June 25 the second phase of its proposed tax reform, which aims to change the income tax legislation for individuals and legal entities, as well as establish new rules for the taxation of profits, dividends, and financial investments. Almost a year after the first phase was presented, the new bill will now[...]

In the midst of the Covid-19 pandemic, Brazilian federal government enacted Law No. 14.026/20, establishing a new regulatory framework for basic sanitation in Brazil. It is true that some 35 million Brazilians (more than 16% of the population) simply cannot stay at home and wash their hands to decrease their contamination’s risk, as they do not[...]

It is well known that the constant increase in the number of Internet users has significantly changed various parts of the economy. Of all of them, one of the most affected is marketing, because the Internet has made it possible for companies’ various strategies to be achieved faster and more effectively by directing actions to specific target[...]

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 arising out from the sale of share control of a company by means of closely-end investment funds (Fundos de Investimentos em[...]

Federal Law 13,428 was enacted in March 30th 2017 ruling the reopening of the Brazilian Special Regime for Tax and Exchange Legalization (“RERCT”), taking into consideration the success of its first version, which represented an extra revenue for tax authorities in 2016 of over BRL 45 billion. The main objective of the regime remains the[...]

1. Brief Introduction to the Brazilian Transfer Pricing Legislation The Brazilian transfer pricing rules were introduced into the local legislation by means of Law 9,430, from 1996, coming into force in 1997. Having been inspired by the US legislation, these rules’ main goal is to prevent the shifting of taxable profits from Brazil to other[...]