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Brazil Adds Ireland to Black List and Austrian Holding Companies to Grey List

On 13 September 2016, Brazil published Normative Instruction RFB No. 1658/2016 in the Official Gazette, which amends Normative Instruction RFB No. 1037/2010 (list of low tax jurisdictions and privileged tax regimes). The main amendments include:

  • The addition of Curacao, Ireland and Sint Maarten as low tax jurisdictions (black list), and the removal of the Netherlands Antilles;
  • The addition of the Austrian holding company regime as a privileged tax regime (grey list); and
  • The addition of a definition for substantial economic activity in relation to Danish and Dutch holding company regimes (grey listed), which essentially states that a holding company is considered to have substantial economic activity if it has the appropriate operational capacity, as evidenced by the existence of a sufficient number of employees and adequate physical facilities, for the exercise of management and effective decisions on:
    • The development of activities in order to obtain income derived from its assets; or
    • The administration of equity in order to obtain income arising from the distribution of income and capital gains.

Inclusion in the black list or grey list impacts several areas of Brazilian taxation, including withholding tax rates, the deductibility of expenses, thin capitalization rules, CFC rules and transfer pricing.

Click the following links for Normative Instruction RFB No. 1658/2016 and Normative Instruction RFB No. 1037/2010 as amended. The changes are effective from 1 August 2016.

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