Weekly Articles

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Brazil’s new tax regime for financial investments, CFCs, and trusts held abroad

By David Roberto R. Soares da Silva Through Provisional Measure No. 1.171/2023 (MP 1171), published in an extra edition of Brazil’s Official Gazette on April 30, 2023, the Lula Government substantially altered the way financial investments abroad, including those made through offshore companies and trusts, should be taxed. If approved by Congress, the new rules […]

The Spanish Beckham Law Tax Regime

By Carlo Lorusso and Almudena Soler Commonly known as “Beckham law,” the Spanish Special Expat Regime is regulated by the Spanish Personal Income Tax Law. According to Article 93, individuals who acquire their tax residence in Spain might choose to be taxed under Spanish Non-Residents Income Tax rules instead of the Personal Income Tax rules […]

Foreign trusts and the Inheritance and Donations Tax in the state of São Paulo

By David Roberto R. Soares da Silva In a recently published ruling, the São Paulo Treasury Department ruled for the first time about the Inheritance and Donations Tax (ITCMD) aspects related to foreign trusts, especially regarding its levy and taxable event.

Tax treatment of foreign trusts in Brazil: A commentary to Bill 145/2022 – Part 2

By David Roberto R. Soares da Silva Part 2 of this work addresses the income tax rules applicable to transactions involving foreign trusts and Brazilian resident parties, contemplated in the Complementary Law Project No. 145/2022 (PLP 145), submitted by lawmaker Eduardo Cury to Brazil’s House of Representatives in late 2022.

Tax treatment of foreign trusts in Brazil: A commentary to Bill 145/2022 – Part 1

By David Roberto R. Soares da Silva Without much fanfare, Brazil’s House of Representatives is reviewing a complementary law project that proposes to regulate the effectiveness of foreign trusts in Brazil and their respective tax treatment. The law project has no relation to the bill already under discussion in Congress on the possibility of creating […]

Brazil’s House Commission Approves CFC Rules for Individuals

By David Roberto R. Soares da Silva At the end of the 2022 legislative year (Dec. 14), the Finance and Taxation Commission (CFT) of Brazil’s House of Representatives approved a bill that ends the tax deferral of profits from offshore companies to individuals (CFC rules).

Understanding Brazil’s Interest on Equity

By David Roberto R. Soares da Silva  Created in 1996, the interest on equity (juros sobre capital próprio, or JCP) is a mechanism available to certain Brazilian companies to compensate their equity holders in addition to profits and dividends.

Automatic exchange of information and expatriates working in Brazil

By David Roberto R. Soares da Silva and Felipe Pereira Louzada In an increasingly globalized world, Brazil proves that workers’ global mobilization is also a reality in emerging countries. But globalization has also added complexity when it comes to tax reporting by expatriates leaving overseas, and Brazil is no different.

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