Law No. 14,973/2024, concerning the amnesty program for assets held in and/or outside Brazil and non-declared to the Brazilian Federal Revenue and to the Brazilian Central Bank (“RERCT 2024”), was published on September 16th, 2024. It presents taxpayers with an opportunity to disclose ownership of undeclared assets held outside the country with the benefits of […]
Category: articles
Draft Law No. 108 of 2024 (“PLP 108”) and the Proposed Amendments to Estate, Inheritances and Gift Tax, Including on Cross Border transactions
Draft Law no. 108 (“PLP 108/24”) comprises the major revision of the Brazilian tax code, was approved last Tuesday, August 13, 2024, by the Chamber of Deputies and will be forwarded to Senate for discussion. In addition to establishing the transition between the current tax system, PLP 108/24 brings relevant proposals regarding the Estate, Inheritance […]
Regulation of Virtual Currencies in Brazil
Until very recently, cryptocurrencies were not specifically regulated in Brazil, unless they met the definition of a security under the Brazilian Securities Law. In December 2022 the President of Brazil sanctioned Law 14,478 setting the rules for virtual assets service providers (‘virtual assets service providers’ or VASPs). Law 14,478 came into effect in June 2023. […]
TAXATION OF FOREIGN FINANCIAL INVESTMENTS, FOREIGN CONTROLLED ENTITIES AND TRUSTS (PL 4.173/2023) OWNED BY INDIVIDUALS
PROJECT LAW PROCESS The Law Project no. 4,173/2023 was sent by the federal government to the National Congress for approval of the plenary of the Chamber of Deputies and the Senate. FOREIGN FINANCIAL INVESTMENTS Taxation of Foreign Financial Investment Earnings: Earnings from foreign financial investments (interest and gains from exchange rate variations on the principal) […]
Resume of Government tie break vote in Tax Disputes at the Administrative level
Initially, the casting vote in favor of the Federal Government was edited, by Provisional Measure MP 1,160, which lost effect on June 1st, returning to the pro-taxpayer tiebreaker at Carf. After an agreement with the president of the Senate, it was decided to send it as a legislative proposal with constitutional urgency. Bill No. 2.384/23. […]
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