The new Brazilian Income Tax Regulation (“New RIR”) was published today after almost twenty years of the existing regulation. New RIR brings updated rules related to the taxation, inspection and collection of the individual income tax, corporate income tax and foreign investors’ income tax.
New RIR has been long expected by the market, since important changes in the Income Tax legislation have been introduced during this long period, such as: (i) transfer pricing and thin capitalization rules; (ii) taxation of financial instruments; and, most important, (iii) the substantial change in the corporate taxation by Law No. 12,973/2014, which modified several topics of the legislation in order to align with IFRS standards.
Please note that a comprehensive tax reform has been under discussion by the Brazilian Government, so New RIR could be reviewed soon.
We are at your disposal to discuss the content of the New RIR and its potential tax implications.