Brazil: Tribunal considers municipal service tax over complex contracts Bruno Porto and Mark Conomy of PwC Brazil discuss the Brazilian Supreme Federal Tribunal’s decision confirming that municipal service tax (ISS) can apply over ‘complex contracts’. By Mark Conomy & Bruno Porto March 04 2021
Brazil: STJ confirms the triggering event for withholding tax Bruno Porto and Mark Conomy of PwC Brazil discuss the Brazilian Superior Tribunal of Justice's decision confirming the triggering event for income withholding tax over foreign debts. By Mark Conomy & Bruno Porto December 09 2020
Brazil: Tax authorities confirm treatment of foreign reimbursements related to partner-... Alvaro Pereira and Mark Conomy of PwC Brazil explain why the RFB’s publication of SC 2006/2020 has confirmed favourable outcomes for certain transactions although the consequences concerning the broader treatment... By Mark Conomy & Alvaro Pereira October 29 2020
The Brazilian tax authorities interpret non-defined terms within a tax treaty Mark Conomy of PwC Brazil explores the implications of a ruling concerning the double tax treaty between Brazil and France. By Mark Conomy September 22 2020
Brazil: STJ confirms tax treaty benefits apply on cross-border services income Alvaro Pereira and Mark Conomy of PwC Brazil take a look at a key STJ decision will assist companies carrying out cross-border transactions. By Mark Conomy & Alvaro Pereira August 07 2020
Brazil takes steps to clarify effect of PIS/COFINS on exports Alvaro Pereira and Mark Conomy of PwC Brazil round up the latest developments from the Brazilian tax authorities on the application of PIS/COFINS over exportations. By Mark Conomy & Alvaro Pereira July 06 2020
Brazil clarifies law on goodwill and step-up deductibility Priscila Vergueiro and Mark Conomy of PwC Brazil set out how Brazilian tax authorities have provided guidance on the definition of ‘dependent parties’ for the purpose of goodwill and step-up... By Mark Conomy & Priscila Vergueiro May 11 2020
Brazilian tax authorities provide guidance on ‘debit to shareholders account’ transactions On July 1 2019, the Federal Brazilian Tax Authorities (RFB) published Solução de Consulta – Cosit 210/2019 (dated June 24 2019), providing that withholding tax should be levied at a... By Mark Conomy & Priscila Vergueiro October 15 2019
Brazil publishes guidance on PIS/COFINS impacts for debt forgiveness Brazil's federal tax authorities have published guidance noting that debt forgiveness ought to be regarded as financial revenue and should be taxed at 4.65%. By Mark Conomy & Priscila Vergueiro February 04 2019
Brazil clarifies tax treatment of international charter leasing payments The Brazilian tax authorities have provided guidance on the application of the reduced 0% income withholding tax rate on international charter leasing payments. By Fernando Giacobbo & Jaime Andrade & Mark Conomy December 12 2018
