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Publications

Here you will find publications by our partners and lawyers with various current topics on the legal and business world.

Tax Implications of Amendments to Foreign Intercompany Loans: Taxation of Gains From Foreign Exchange Variation, IOF-Exchange Tax & New Transfer Pricing Rules on Interest

I. Introduction

This article analyzes the tax implications derived from amendments to foreign loan agreements denominated in foreign currencies registered at Brazilian Central Bank (“BACEN”), specifically regarding the taxation of foreign exchange variation gains under the cash basis method, when elected by Brazilian taxpayers (“Companies”). 

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International Tax Planning in Brazil: What to Expect Following Recent Case Law

1. Introduction

As a result of globalization, international tax planning has become a difficult topic for tax authorities worldwide. In particular, the development of more complex and refined cross-border business arrangements has made it difficult for states to distinguish abusive legal structures from the valid or legitimate ones. As time has passed, the relative liberty granted by the governments to investors to structuring overseas business activities have been significantly curtailed. After appreciating the increasing erosion of their income tax base, most states have started to develop mechanisms to challenge and prevent abusive structures that, ultimately, had adverse effects for their economies.

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Permanent Establishment under Brazilian Domestic Law: Tax Implications of Foreign Enterprises Carrying Out Business in Brazil in the Absence of a Double Tax Treaty

I. Introduction

This article analyzes the tax implications of foreign companies and enterprises (“Foreign Enterprise”) carrying out their business (partially or entirely) in Brazil, in particular when these activities could give rise to tax liability to the Foreign Enterprise due to the creation of a tax nexus in the Brazilian territory similar to the characterization of a “Permanent Establishment” concept normally adopted by Brazil in its double tax treaties (DTT) currently in force with other countries. 

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Taxation of Cost-Sharing Contractual Arrangements in Brazil: Recent Developments and Current Status

I – General Comments on Cost-Sharing Arrangements and Shared Service Centers

For a long period of time, multinational companies seeking to improve their business efficiency have been adopting cost-sharing arrangements (also known internationally as Cost Sharing Agreements – “CSA” or Cost Contribution Arrangements – “CCA”) involving back-office or administrative activities that benefit more than one company of the same economic group. Normally, services of this nature are used and benefit several or all of the companies that are part of such economic group. Hence, in order to reduce the compliance costs, save time and optimize efforts, as well as centralize all management of such type of ancillary services, the group elects one company, the Leader, to execute and consolidate these non-core/back-office activities on behalf of the other Beneficiaries.

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