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Leandro Andrade

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Brazilian Revenue Service publishes Public Consultation to regulate the APA’s 29 August 2024

The Brazilian Federal Revenue Service published yesterday, 28.08.2024, a Public Consultation on the Normative Instruction that will regulate the specific consultation procedure for proposing an Advance Pricing Agreement (APA). Taxpayers and interested parties will be able to send comments and suggestions on the text proposed by the tax authorities[...]


BRAZILIAN TAX REVIEW – AUGUST 2023 17 August 2023

Subsidies for investment – Issue 1.182. On April 26, 2023, Brazil’s high tax court, the Superior Court of Justice (‘STJ’), defined the possibility of excluding tax benefits related to the State Value-Added Tax on the Circulation of Goods and Services (ICMS), such as reduction of the basis for calculation, rate reduction, exemption,[...]


BRAZILIAN TAX REVIEW – APRIL 2023 26 April 2023

New Brazilian transfer pricing rules can already be used by companies as from fiscal year 2023 At the end of 2022, the Brazilian Federal Revenue Bureau (RFB) published Provisory Measure (MP) 1152/2022, which altered the nation’s transfer pricing rules, bringing them more into line with the rules applicable under the Organization for Economic[...]


BRAZILIAN TAX REVIEW – JANUARY 2023 26 January 2023

Norway and Brazil sign new Treaty to avoid Double Taxation On November 4th, 2022, Brazil signed an international agreement with Norway that, among other things, would eliminate double taxation on income, as well as prevent tax evasion. The purpose of the new agreement is to update and modernize – based on best international practices –[...]


BRAZILIAN TAX REVIEW – OCTOBER 2022 11 October 2022

Brazilian Network of Conventions to Avoid Double Taxation Expands As from the beginning of next year (January 1, 2023) Decree 11.109/2022, which was enacted in June of this year, takes effect to avoid double taxation between Brazil and the major Southeast Asian market hub, the country of Singapore. Moreover, in August of this year, Brazil[...]


BRAZILIAN TAX REVIEW – JULY 2022 19 July 2022

Brazil’s Federal Supreme Court (STF) Suspends Reduction of Excise Tax (IPI) Granted by Federal Government In February of 2022, the Brazilian Federal Government issued a Decree reducing the federal Excise Tax (IPI) by as much as 25% for most products sold in Brazil.  In April, it issued a new decree upping the IPI reduction to 35%, except for[...]


BRAZILIAN TAX REVIEW – DECEMBER 2021 4 January 2022

Brazilian Federal Supreme Court (STF) rules on state value-added tax (ICMS) on electric power and telecom services The Brazilian Federal Constitution established that States may assign different ICMS rates depending on the product or service sold.  Nevertheless, it is necessary to observe the selectiveness of such goods and services since[...]


BRAZILIAN TAX REVIEW – OCTOBER 2021 27 October 2021

Superior Court of Justice – STJ overturns late payment fine on federal taxation of imports supported by Drawback-Suspension 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 of non-compliance with[...]


BRAZILIAN TAX REVIEW – JUNE 2021 18 June 2021

The Supreme Court Has Finally Decided the So-Called “Case of the Century” The Supreme Court has finally decided the case that deals with the exclusion of ICMS tax from the PIS and COFINS tax calculation bases. Although a decision had been entered in March of 2017, a motion for clarification was pending. By majority opinion, the Supreme[...]


Brazilian Tax Review – April 2021 14 April 2021

Supreme Court Schedules the Trial of the so-called "Tax Case of the Century" The Supreme Court has scheduled the hearing of a motion for clarification of a decision that deals with the exclusion of the ICMS tax from the PIS and COFINS tax calculation bases for April 29, 2021. In 2017, the Supreme Court ruled that the ICMS tax must be[...]



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