Industries and markets

Brazil: Transfer Pricing – RFB explains PRL Usage

The RFB (Receita Federal do Brasil) has introduced the Consultation Solution Nr. 95-Cosit which confirms that companies that import goods from affiliates abroad need to comply with the transfer pricing rules. It does not matter

Brazil: Calculation Base for Import Tax corrected

The Highest Court STJ hat decided that expenses for goods movement on Brazilian territory cannot be included in the calculation base for the import tax (see judgment from the 1st Panels of the STJ, special

Brazil: Hope for IRPJ and CSLL Refunds

 Law No. 13.670 / 2018 has changed Article 74 of the Law No. 9.430 / 1996 which ends the practice of calculating the monthly IRPJ (capital gains tax) and CSLL (social security contributions) based on

Argentina: CbC News for MNE

The Argentinian tax authority AFIP has published additional information on the interpretation and filing requirements of the CbC rules (country-by-country) (AFIP Resolution 4130 changed by Resolution 4332). It has amended them by answering to an

Brazil: New Data Protection Law

In Brazil, Law No. 13.709 /18 provides the first general regulation on data protection. The goal of the new law is to regulate the handling of personal data, also for digital media, as well as

Brazil: Social Security Contributions on Tax Stamps remain

Recently, the highest chamber of the Administrative Committee of Tax Consultants (CARF) received a note from the Ministry of Finance stating that gains – such as the supplementary payment for food from employers to employees

Brazil: TRF3 and tax loss carry-over

Recently, the district court of the 3rd region (TRF 3) has passed a judgment regarding limits for compensating tax losses of merged companies and companies facing bankruptcy. This created an important precedent for taxpayers. Precedent

Obrador moves to scrap Mexico’s controversial education reforms

“AMLO has proposed a new plan that would scrap teacher evaluations and make public education free. But many say the government can’t afford to do that.”

Brazil: Precedent for Calculation of Debt Balance for “Refis in Crisis”

One of Brazil`s debt relief programs is called “Refis in Crisis” (Refis = Recuperacao Fiscal) as is aimed at companies that want to pay their tax debt in installments. The calculation of the actual debt

Brazil: Balancing of Leasing Contracts adapted to International Standards

Up until now, the balancing of leasing contracts in Brazil depended on their classification either as Finance-Leasing or Operate-Leasing. This classification will be discontinued starting January 1st, 2019 in order to comply with international standards.