The Full Bench of the Supreme Court (Supremo Tribunal Federal – STF) recently addressed the application of the Real Estate Transfer Tax (Imposto de Transmissão de Bens Imóveis – ITBI) to the transfer of real estate as a capital contribution, in accordance with the immunity provided under Article 156, item II, of the Brazilian Federal […]
Category: articles
New Tax Amnesty Program
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 […]
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) […]
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