Category: Brazil

Switzerland: The Brazil And Switzerland Double Tax Treaty: Why Is It So Significant?

Background The Brazilian and Swiss Governments signed a Double Tax Treaty (DTT) on 3 May 2018. Switzerland is one of the biggest investors in the Brazilian market and Brazil and Switzerland have already signed an Automatic Exchange of Information Agreement, which came into force on 1 January 2018. This new… – Continue reading

Brazil and United Arab Emirates sign agreement to eliminate double taxation

Convention signed on Monday will facilitate investments, can reduce tax evasion Brazil and the United Arab Emirates signed an agreement to eliminate double taxation on income and prevent tax evasion and tax avoidance. The document was signed on Monday (12 November) by Brazilian Foreign Minister Aloysio Nunes Ferreira and UAE… – Continue reading

Neymar Fined $1.2 million Over Tax Case Delays

New Delhi: Star striker Neymar Jr is fined 3.8 million reais ($1.2 million) by a Brazilian court for attempting to “obstruct the continuity” of a tax evasion case. The penalty applies to the Paris Saint-Germain player, his parents and three companies that manage his finances, according to the federal regional… – Continue reading

Sao Paulo Property Secrecy Exposes Continuing Role of UK Tax Havens

A new report from Transparency International has revealed that more than US$2.7 billion worth of property in Sao Paulo, Brazil’s biggest city, is hidden behind shell companies, many of which have close links to the United Kingdom, which has many offshore tax havens in its overseas dependencies. Using newly released… – Continue reading

Sao Paulo Property Secrecy Exposes Continuing Role of UK Tax Havens

A new report from Transparency International has revealed that more than US$2.7 billion worth of property in Sao Paulo, Brazil’s biggest city, is hidden behind shell companies, many of which have close links to the United Kingdom, which has many offshore tax havens in its overseas dependencies. Using newly released… – Continue reading

Brazil’s Petrobras Loses Appeal of Double Taxation

For the second time in 14 months, Brazil’s state oil company Petrobras has lost a dispute over Brazil’s recognition of tax treaties. On March 24, a federal revenue service appeals court ruled against Petrobras in a $510 million case (16682.721067/2014-01) involving the company’s profits in the Netherlands for 2010. Although… – Continue reading

Brazil Outlines Process for Asking International Tax Questions

Brazil’s federal revenue service is continuing to adapt the country’s tax rules to OECD recommendations, as shown in recent guidance on how companies should seek help from the government on international tax questions. Normative Instruction 1689, issued Feb. 21, spells out the requirements for companies to request a consultation on… – Continue reading

New transfer pricing requirements in Latin America under BEPS

Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative. In this new year, Mexico, Colombia and Peru have included in their local legislation new documentation requirements that follow a three-tiered approach: country-by-country (CbC) report, master file,… – Continue reading

Brazil and Switzerland agree to automatic exchange of financial account information in tax matters

The Governments of Brazil and Switzerland have released a joint declaration expressing their intent to introduce, on a reciprocal basis, an automatic exchange of financial account information in tax matters based on the OECD Common Reporting Standard, beginning in the year 2018. The first transmission of data will take place… – Continue reading

Switzerland eyes AEOI with 21 countries

Switzerland, which has been working to end its years-long practice of banking secrecy, on Thursday said it aimed to dramatically increase the number of countries it cooperates with toward international fiscal transparency. The Swiss government said in a statement that it wanted to extend the automatic exchange of information (AEOI)… – Continue reading

Taxman targets Real and Barca over fraud, says report

Giants Real Madrid and Barcelona are among five La Liga clubs from whom the Spanish taxman is looking to recover €52 million (RM244 million), online newspaper El Confidencial claimed yesterday. Alongside Atletico Madrid, Sevilla and Valencia, the big two are accused of having avoided tax by paying player’s agents directly…. – Continue reading

Automatic exchanges signed with three countries

Switzerland has signed declarations to exchange tax information automatically with Brasil, Mexico and Uruguay and Mexico in coming years, but the deals must still go before Swiss parliament for approval. Under the declarations, banking information would be collected from 2018 and exchanged by 2019, the State Secretariat for International Financial… – Continue reading

Deal signed to counter profit shifting Read more at: http://www.iomtoday.co.im/news/isle-of-man-news/deal-signed-to-counter-profit-shifting-1-8198001

New Chief Minister Howard Quayle MHK has restated the island’s commitment to tax transparency at an Organisation for Economic Co-operation and Development event in Paris. Mr Quayle was in Paris for the Manx government’s signing of a new OECD agreement on automatic exchange of country by country reporting by large… – Continue reading

Gov’t, Chile agree deal to end ‘double taxation’

Argentina and Chile yesterday announced the implementation of a long-awaited agreement to eliminate double taxation for residents of both countries in order to encourage investment and prevent tax evasion. Chile’s Foreign Minister Heraldo Muñoz, Public Works Minister Alberto Undurraga, and Finance Minister Rodrigo Valdés met with Argentina’s Finance Minister Alfonso… – Continue reading

Tax havens are under attack

Ireland, accused of being a tax haven for multinationals such as Apple to pay nearly zero tax on the bulk of its profits earned outside the United States, finds itself with a new adversary in the global fight against unfair tax practices — Brazil. As of October 1, Brazil will… – Continue reading

Multilateral Tax Pact To Take Effect In Brazil In October

The Multilateral Convention on Mutual Administrative Assistance in Tax Matters is set to come into effect in Brazil on October 1, 2016, following the publication of Decree No. 8842 in the Official Gazette on August 30. According to the Organisation for Economic Cooperation and Development (OECD), the Convention is the… – Continue reading

Bank secrecy rules face ‘lethal blow’ in Uruguay

Gov’t sends bill to Congress to force banks to share account data automatically Described by government officials as a “lethal blow” to bank secrecy, Uruguay has sent a bill to Congress that will force banks to automatically provide the DGI tax bureau information on the accounts held by individuals and… – Continue reading

Corporations paid no tax at Rio Olympics

Coca-Cola, McDonald’s, Visa and the rest of the corporate sponsors of the August 5–21 Olympic Games in Rio de Janeiro won’t be paying any taxes on the money they earn due to a tax exemption law that is set to cost Brazil hundreds of millions of dollars. The exemption, which… – Continue reading

Deals Canada signed to catch tax cheats allow billions in taxes to escape

Montreal-based clothing maker Gildan earned $396 million in profit last year, but paid just over $6 million in cash taxes — a rate of about two per cent. Drug maker Valeant, based in nearby Laval, Que., booked $1.1 billion in profit in 2014 but paid only $110 million in tax…. – Continue reading

Barcelona accept to pay 5.5-million-euro fine over tax evasion charges on Neymar transfer

Barcelona on Monday accepted to pay a 5.5-million-euro ($6.2 million) fine over Neymar’s contested 2013 transfer in a deal with prosecutors that sees the club avoid trial on tax evasion charges. “It was better to accept this agreement than continue on with the uncertainty that has dragged on for a… – Continue reading

Brazil, Jamaica and Uruguay expand their capacity to fight international tax avoidance and evasion

Jamaica and Uruguay today signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters and Brazil deposited its instrument of ratification of the Convention on the occasion of the launch of the OECD’s Latin American and Caribbean Regional Programme and the OECD Ministerial Council Meeting. Jamaica and Uruguay became… – Continue reading

Why We Should Be Really Worried About the Panama Papers

History shows us that tax evasion can have terrible effects, from economic inequality to societal collapse. In a world seemingly inured to financial scandals, the Panama Papers leak has reminded us of their capacity to shock. This huge document dump, which has revealed thousands of offshore accounts held in the… – Continue reading

Private Eyes They’re Watching You – Offshore Planning after the Panama Papers

Overview If you have been reading my articles on JD Supra for a while, you will know that I love Afro-Cuban and Brazilian music. Nevertheless, the Hall and Oates song Private Eyes, is a more fitting song to describe the state of offshore planning in Tax Havens than “Oye Como… – Continue reading

Industry needs to be more transparent and credible: Jaitley

As “Panama Papers” expose the world’s most prominent people engaging in murky deals, Finance Minister Arun Jaitley on Monday told the Indian industry to become more “transparent and credible” in its functioning. “With the G20 (countries’ new global transparency standard) and FATCA (the US’ Foreign Account Tax Compliance Act) coming… – Continue reading

20 Caribbean, Latin American Nations Named Major Money Laundering Countries

Twenty Caribbean and Latin American nations have been named by the U.S. as “major money laundering” countries in the 2016 International Narcotics Control Strategy Report (INCSR) from the U.S. State Department released Wednesday, Mar. 2, 2016. A major money laundering is defined by statute as one “whose financial institutions engage… – Continue reading

A tax haven professes to stand on principle, risking pariah status

PANAMA’S most notorious moment as a haven for tainted cash came with the nationalisation of money-laundering in the 1980s under Manuel Noriega, a military strongman. It has since clamped down on egregious financial criminality, but remains home to thousands of secretive firms and famous for the discretion of its bankers… – Continue reading

Brazil: study abroad exempt from new overseas payment tax

Study abroad programmes will be exempt from a new 25% tax on overseas payments that was announced last week, the Department of Federal Revenue has announced, prompting a sigh of relief among stakeholders that send and receive Brazilian students abroad. The new levy prompted widespread concern in the study abroad… – Continue reading

Ireland’s new growth a model for other nations, Enda Kenny tells Davos forum

Ireland’s emergence from economic meltdown provides a model for other nations, the Taoiseach has told the World Economic Forum. Enda Kenny also defended his country’s tax arrangements with multinational companies, telling the audience past claims that it was a tax haven for big businesses were without foundation. Mr Kenny took… – Continue reading

Lionel Messi’s tax fraud trial conflicts with Copa America

MADRID (AP) – Lionel Messi’s tax fraud trial has been set for May 31-June 3, conflicting with the start of the centennial Copa America in the United States. The Copa America Centenario will kick off June 3, meaning the five-time world player of the year will not have the best… – Continue reading

Brazil offshore tax amnesty signed into law

Residents of Brazil with undeclared offshore assets can now voluntarily declare and regularise their tax affairs without facing criminal prosecution and only face a one-off charge and penalty. All individuals and legal entities who were resident or domiciled in Brazil on 31 December 2014, can voluntarily declare previously undisclosed goods… – Continue reading

Brazil’s Rousseff signs amnesty to undeclared offshore assets

BRASILIA, Jan 14 (Reuters) – Brazilian President Dilma Rousseff on Thursday signed a bill that gives amnesty to holders of undeclared offshore assets in exchange for a fine, part of efforts to cut a swelling budget gap and revive investment in the recession-hit economy. The law offers amnesty from prosecution… – Continue reading

Brazil: Tax Treaty Series: The Bilateral Income Tax Treaty Between Brazil And Canada

This is the first of our series of posts on Brazilian tax treaties. In each post we will provide an overview of a specific tax treaty between Brazil and a particular foreign country, as well as comments on any Brazilian administrative or judicial precedents applying the treaty, and highlights on… – Continue reading

Nigerian transfer pricing regulations: Any safe harbour?

The Nigerian Transfer Pricing (TP) Regulations officially known as Income Tax (Transfer Pricing) Regulations No 1, 2012 regulates transactions between connected taxable persons (controlled transactions). The regulation seeks to ensure that transactions among connected taxable persons are carried on at arm’s length. Applying the arm’s length principle to controlled transactions… – Continue reading

Retrospectiva2015: Angolan diplomacy in the context of diversification of the economy

Luanda – Throughout the year just ended, as in the previous, the country’s economy “found himself grappling” with a major setback if they can be considered, due to the continued drop in oil prices, which is in the house $ 37 a barrel, far from the historic $ 122 value,… – Continue reading

Brazil: Dutch holding companies again identified as “privileged tax regimes”

Dutch holding companies have been again included on the Brazilian government’s list of “privileged tax regimes.” Accordingly, this action has implications for purposes of the transfer pricing, thin capitalization, and tax deductibility rules. Background Under Brazilian tax law, the concept of “privileged tax regimes” is relevant for determining: Whether Brazil’s… – Continue reading

Latin America business potential for Island

The World Captive Forum takes place in Florida next month Bermuda’s business chiefs will be out in force at next month’s World Captive Forum. The event, to be held in Florida, will include several speakers from Bermuda including lawyers, regulators and business leaders. And Bermuda delegates will use the event… – Continue reading

Dutch tax treatment of Brazilian ‘interest on equity’ payments as of 2016

On 15 September 2015, the Dutch government released its budget for 2016, containing the Tax Plan 2016, which includes certain amendments to Dutch tax law. One of the proposed amendments was the inclusion of an anti-hybrid rule in the Dutch participation exemption regime (“PER”). On 22 December 2015, the amendments… – Continue reading

Is It the Real Thing? The IRS Makes $9+ Billion of Transfer Pricing Adjustments Against The Coca-Cola Company

On September 17, 2015, the IRS issued a statutory notice of deficiency to the Coca-Cola Company, increasing its federal income taxes for 2007-2009 by $3.3 billion, based primarily on transfer pricing adjustments exceeding $9 billion. On December 14, 2015, Coca-Cola petitioned the U.S. Tax Court to overturn the adjustments. This… – Continue reading