Brazil has published Private Ruling No. 8014 of 25 June 2019 in the Official Gazette, which clarifies the transfer of tax credits in case of a partial corporate spin-off. The Ruling provides that a partial corporate spin-off without economic purpose should be disregarded when it has the purpose of recognizing a tax credit of any kind for the purpose of tax off-set, reimbursement, etc.
However, if a partial corporate spin-off is carried out with economic purpose, it will be recognized as a …