On September 29, the Brazilian IRS (“SRFB”) published Normative Ruling RFB nº 2,161/2023 (“IN 2,161/23”), in order to regulate the new transfer pricing system introduced in Brazil through Law nº 14,596/2023. One of the main points of attention is the postponement – until December 31st – of the deadline to opt for the early adoption […]
In brief We inform you that on September 21, 2023, it was enacted the Law no. 14,689/2023, as a result of the sanction, with vetoes, by the Vice-President of the No. 2,384/2023, with the purpose of disciplining the proclamation of judgment results in the event of a tie vote within the scope of the Administrative Council […]
Trench Rossi Watanabe was named “Brazil Tax Firm of the Year” at the 18th International Tax Review (ITR) Americas Awards. This year, we were also shortlisted in the “Transfer Pricing Firm of the Year” category while partner Clarissa Machado was nominated as “Latin America Transfer Pricing Practice Leader of the Year.” Clarissa represented the firm at the […]
In brief On September 11, 2023, the Brazilian Supreme Court (“STF”) issued a significant ruling concerning the constitutionality of clauses within collective agreements, such as collective bargaining agreements and agreements between companies and Workers’ Unions. In more detail The STF’s decision declares that clauses establishing mandatory union assistance contributions, applicable to both employees and companies, […]
The 2024 edition of the World Tax guide, promoted by ITR (International Tax Review), was released. We were recognized in three categories in the highest classification (Tier 1): Tax Controversy, Transactional Tax and Transfer Pricing. We were also ranked in Indirect Tax and General Corporate Tax. In terms of individual results, nine of our lawyers were […]
Scope of the Provisional Measure No. 1,185 (“MP 1,185”) The MP 1,185, published on August 30, 2023, revoked, as of January 1, 2024, the existing legal provisions relating to (i) the exclusion of investment subsidies from the IRPJ and CSLL (corporate income taxes) basis, and (ii) the non-levy of PIS and COFINS (turnover contributions) on […]
On August 28, 2023, the federal government submitted to the National Congress the Bill of Law n. 4.173/2023 (“PL”) that provides for the taxation of income earned by individuals residing in the country in financial investments, controlled entities and trusts abroad. The content of the bill is similar to that presented in Provisional Measure 1,171/23 […]
In brief We inform you that on August 30, 2023 (Wednesday), the Bill No. 2,384/2023 was approved, with the purpose of disciplining the proclamation of judgment results in the event of a tie vote within the scope of the Administrative Council of Tax Appeals (CARF), among other measures connected to tax litigation and the transaction […]
In brief On August 28, 2023, the Provisional Measure No. 1,184 (MP) was published, which provides for the taxation of investments in investment funds in Brazil. The MP enters into force on January 1, 2024, provided that the MP is converted into Law in 60 days, extendable for another 60 days. However, the articles proving […]
