The taxation of income earned by controlled and related foreign companies has become an increasingly important question as Brazil’s economy develops, since a growing number of Brazilian businesses now have investments in foreign companies that constitute a relationship of control explains Maurício Pereira Faro of Barbosa Müssich & Aragão.
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Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort