Brazilian Tax Highlights - An overview for foreign investors

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Brazilian Tax Highlights - An overview for foreign investors
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                Brazilian Tax
                Highlights

                An overview for foreign
20 April 2017   investors
Brazilian Tax Highlights - An overview for foreign investors
Contents
      Tax transparency

      Cash repatriation

      Q&A

      Appendices

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Brazilian Tax Highlights - An overview for foreign investors
Tax transparency and efficiency in Brazil

               1           CbCR and MCAA

               2           Exchange of information on tax
                           rulings

               3          Identification of beneficial owners

               4           Simplification

               5          Tax audits in Brazil

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Brazilian Tax Highlights - An overview for foreign investors
Tax transparency and efficiency in Brazil

               1          CbCR and MCAA

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The BEPS initiative
      Due to recent cases of abusive tax planning implemented by multinational enterprises, and political
      pressures for organizations to pay their fair share of taxes, the Organization for Economic Cooperation and
      Development (OECD), together with the G20 countries, has been exploring alternatives to combat abusive
      practices since 2013. The Base Erosion and Profit Shifting (BEPS) initiative was then created to help
      closing the gaps in international taxation. In October, 2015, the OECD issued the final recommendations
      on the 15 Action Items of the BEPS. These measures range from new minimum standards to revision of
      existing standards, and countries are committed to this comprehensive package and to its consistent
      implementation.

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The BEPS initiative & Brazil

      •   July, 2013 - Brazilian IRS first manifested the intention to participate in the BEPS initiative.
      •   18 June, 2014 - National Congress authorized the Country’s formal participation (Law #12.995).
      •   Brazilian IRS understands that recent changes to Brazilian legislation already comply with other
          Actions proposed under the BEPS initiative, such as: Transfer Pricing (new deductibility rules for
          interest payments, new fixed profit margins and calculation methodologies); stricter CFC rules
          (very efficient to prevent base erosion and profit shifting); thin capitalization rules; and
          adjustments to the tax havens’ list, plus stricter rules for remittances to these countries.
      •   Actions 5 and 13 were partially adopted by the Brazilian IRS, by means of certain normative
          instructions which focused on minimum standards agreed in these actions, for purposes of
          demonstrating transparency and substance of the companies’ activities.

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What is Action Plan 13?

      1         2           3

                                        Overview of the global business of the
                                        multinational enterprise, transfer pricing
      Master File                       policies and allocation of income and
                                        activities.

                                                Detailed transfer pricing information of
                                                transactions taking place between the
               Local File                       entities of the jurisdiction with related
                                                parties and financial information of those
                                                transactions.

                                                           Wide information and indicators related
                                                           to the business of the group including
                        Country-by-Country Report          global allocation of income, taxes paid
                                                           and due for each entity of the group.

                                      Normative Instruction 1,681/2016

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Normative Instruction
  1,681/2016
 Normative Instruction* 1,681/2016, issued on 29 December, 2016,
 establishes the framework under which multinational enterprise groups
 would be obliged to disclose information in Brazil regarding the Country-
 by-Country Report (CbCR)

                              The ultimate parent company may be obliged
                               to file an annual CbCR in Brazil if the group’s
                                annual consolidated revenues exceed either
                                 BRL 2.26 billion or EUR 750 million
                              (depending on whether the ultimate controller
                                        is a Brazilian resident or not).

      *The Normative Instructions issued by the Brazilian Federal Revenue Service constitute ancillary normative acts to the laws, treaties,
      international conventions and president decrees, which serve to regulate the taxes and the taxpayers activities. As complementary
      standards, their validity and effectiveness depend on compliance with the above mentioned primary normative acts.

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Normative Instruction
      1,681/2016
          Who is obliged to              Where and When the CbCR                 Penalties
      prepare the CbCR in Brazil             needs to be filed

       Ultimate controlling entity       To be filed with the          Entities failing to file,
        of the group, resident for tax     Brazilian Income Tax           filing late: fines ranging
        purposes in Brazil;                Return: ECF – Electronic       from BRL 500/ month;
       Substitute reporting entity;       Tax Bookkeeping;               and
        or                                First filing deadline will    3% on any amount that
       Subrogate entity resident for      be on 31/07/2017,              has not been declared or
        tax purposes in Brazil             regarding tax year             that was inaccurately /
        (under certain situations,         beginning on 1 January,        incompletely reported.
        such as systemic failures).        2016.

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Normative Instruction
      1,681/2016
                                                                                 Increasing substance,
                  Relevant aspects to be considered                              transparency and consistency!

      1   Joint Venture investments should be reported in the CbCR by one
          of its shareholders (the investors should define who will perform
          this obligation).

          Financial information should be disclosed with the full amount
      2   registered in the financial statements (i.e.: 100%) of each entity,
          regardless of the participation interest of the ultimate controlling
          entity in those investments.

      3   Information should be reported using the currency of the group’s
          ultimate controlling entity.

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Multilateral Competent Authority Agreement (MCAA)

The Amended Convention on Mutual Administrative Assistance in Tax Matters signed by Brazil in
2011 entried into force in 01 October 2016.

On 21 October 2016, Brazil joined the Multilateral Competent Authority Agreement for the automatic
exchange of CbCR, which is based on article 6 of the Convention on Mutual Administrative Assistance in Tax
Matters, as amended by the 2010 protocol.

On the same day, Brazil signed the CRS Multilateral Competent Authority Agreement, re-confirming its
commitment to implementing the automatic exchange of financial account information pursuant to the
OECD/G20 Common Reporting Standard (CRS) in time to commence exchanges in 2018.

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CbCR in practice if the group fails into CbCR scope…

• From a French standpoint, the French subsidiary of a Brazilian group, on its tax form 2065 (2017
printout to be filed with FY16 tax return), has to :
      •   Tick a box where the French affiliate of a foreign group is responsible for filing the CbCR; or
      •   Mention the name, address and country of the company (located in France or in a country subject to
          the CbCR requirement such as Brazil) which is responsible for filing the CbCR (provided MCAA has
          been signed).

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CbCR in practice if the group fails into CbCR scope…

•   From a Brazilian point of view, the Brazilian subsidiary of a foreign group:
    1.     Has to indicate in Brazil basically which is the ultimate controlling entity of the group and fill the form
           with all the details of this entity, such as its fiscal jurisdiction and tax identification number (TIN),
           provided that the ultimate controlling entity of the group (or another entity indicated by the group as
           the substitute one) complies with the following conditions:
                 i.     Is located in a jurisdiction where the filing of the CbCR is already in force with the same
                        content required in Brazil;
                 ii.    Has already signed the MCAA for the automatic exchange of the CbCR;
                 iii.   Files the CbCR in a period no longer than 12 months from the last day of the fiscal year
                        reported (specifically required only for the substitute entity);
                 iv.    Is not located in a jurisdiction that have already notified the Brazilian tax authorities or been
                        notified by them in relation to the occurrence of systemic failure in exchanging the CbCR;

           OR

      2.    Must also file the CbCR in Brazil, as the surrogate entity, in case the Brazilian subsidiary is held by a
            group established in a country which fails to comply with any of the above mentioned conditions.

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Tax transparency and efficiency in Brazil

               2          Exchange of information on tax
                          rulings

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Exchange of information on tax rulings
•    Normative Instruction 1,689/2017, in force as from 21 February 2016, regulates the exchange of
     information on tax rulings within the framework of improving transparency relating to rulings under
     Action 5 of the BEPS Action Plan.
•    Under this instruction, any private rulings (solução de consulta) or divergence rulings (solução de
     divergência) on the following topics may be object of exchange of information:
       transfer pricing;
       tax incentive related to PADIS; and
       permanent establishments.
•    Taxpayers requesting rulings on those topics must state in their requests:
       identification of the direct or final controller of the legal entity requesting the ruling, as well as its country of
        residence (if it is located abroad); and
       the country of residence of:
           – all related parties with whom the taxpayer carries on transactions relating to the topic under consultation; and
           – the head office and the permanent establishment, when the ruling request is related to permanent
           establishments.
•    A summary of these tax rulings will be submitted to the tax authorities of the jurisdictions included in
     the scope of the consultation with whom Brazil has a signed agreement for exchange of information*.
    *Brazil has not yet signed any specific agreement for exchange of information related to rulings, such as the MCAA for the automatic
    exchange of the CbCR. The provision of administrative assistance in DTTs, like article 26 of the France-Brazil Treaty may be not sufficient.
    The Brazilian tax authorities have not yet formally issued any further clarification on this matter.

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Tax transparency and efficiency in Brazil

               3         Identification of beneficial owners

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Identification of beneficial owners
•     On 09 May 2016 the Brazilian tax authorities issued NI 1.634 establishing the obligation to disclose
      information related to final beneficiaries (and the foreign holding chain) of Brazilian companies in the
      national registry of legal entities (“CNPJ”).

•     According to NI 1.634, the term “final beneficiaries” refers to (i) an individual who ultimately, either
      directly or indirectly, holds, controls or significantly influences an entity; or (ii) an individual on whose
      behalf a transaction is undertaken. A shareholder is deemed to have significant influence if (i) owns more
      than direct or indirect 25% of the entity’s capital stock or (ii) has the ability to influence the decision-making
      and elect or appoint members of the entity’s management.

•     Note that, among others, legal entities set up as listed companies in Brazil, or in jurisdictions which impose
      the public disclosure of information of relevant shareholders (e.g. European countries), as well as non-profit
      entities, were not required to comply with this obligation unless the entities were located in tax havens or
      subject to privileged tax regimes under the Brazilian tax legislation.

•     For these entities, on the other hand, NI 1.634 establish the obligation to inform in the “QSA” of the CNPJ
      the individuals who legally represent them, their direct controllers (in some cases), executive managers and
      directors, as well as any individuals or legal entities for which those entities were incorporated.

•     Although the disclosure of the final beneficiaries was initially set to start on January 1, 2017, NI 1,684/2016
      has postponed the general starting date to July 1, 2017. As an exception, companies registered in Brazil
      before July 1, 2017 will have time until December 31, 2018 to comply with the disclosure obligation
      (however, if a Brazilian company updates its CNPJ before December 31, 2018 for any other reason, the
      disclosure obligation will arise at the date of such change).
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Tax transparency and efficiency in Brazil

               4          Simplification

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Simplification of tax compliance burden
Time spent to comply with tax obligations (in hours per year)

                                                                       Source:
                                                                       Paying Taxes 2017 : the global
                                                                       pictures
                                                                       (www.pwc.com/payingtaxes)

  •   On 2 February 2017, the government announced that a proposal for the simplification of the
      calculation and payment of taxes is under development.

  •   The proposal intends to reduce the time taxpayers spend on calculating and paying taxes from the
      current 2038 hours a year to 600 hours a year (details of this proposal are still to be announced by
      the Ministry of Finance).

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Tax transparency and efficiency in Brazil

               5          Tax audits in Brazil

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Focus of tax authorities in 2017:

On 2 March 2017, the tax authorities announced the targeting plan for tax inspections in 2017, such as:

          tax planning related to corporate reorganization resulting in generation of depreciable assets and also
           involving equity investment funds;

          taxation of foreign controlled and affilliated companies for Brazilian CFC purposes;

          tax evasion:
             –through the use of the exemption on distribution of dividends, where the dividends are
             distributed in an amount higher than the taxed one under the presumed profit method; and
             –in the fuel, cigarette and beverage industries; and

          non-payment of individual income tax by independent professionals.

•     The tax authorities recently announced that information available on social media is used by tax
      officials to analyse and select taxpayers for tax inspections. Relevant information typically relates to
      ownership of goods and the existence of interposed persons. The information available is also used as an
      extra element to confirm or contradict information provided by official sources such as financial
      institutions, notaries and withholding agents.

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Tax audits in Brazil – tentative timeline
“Life Cycle” of an Administrative Federal Tax Dispute in Brazil

      May 01st,               May 31st,              November 3oth,                  December 3oth,              December 3oth,                     January 15th,
      2017                    2017                   2018                            2018                        2020                               2021.

                                                                                                                                                          Divergence Special
             Tax               Defense by                                                                                 Decision of the              Appeal* by the taxpayer
                                                         Decision of the FTA             Voluntary Appeal
         assessment             Taxpayer                                                                               Administrative Tax              or the National Treasury
                                                       (“DRJ”). The FTA may              by the taxpayer in
            (usually            within 30                                                                                Appeals Council                    Attorney’s Office
                                                       drop, confirm or partly                case of a
          preceded by
                              days from the                                                                           (“CARF”). CARF may                  (“PGFN”) in case of
         notification of                               modify its assessment              confirmation or
                                 date of                                                                              confirm or modify the              rejection or success,
        the taxpayer to                                without any time limit                  partly
                              receipt of the                                                                         decision of DRJ without               respectively, of the
            present                                      (the response may last           modification of
                                   tax                                                                                  any time limit (the              Voluntary Appeal (15
          documents/                                    about 1,5 year, based on        the tax assessment
                                                                                                                     response may last about 2
         clarifications)       assessment                       statistics)                  (30 days)                                                           days).
                                                                                                                     years, based on statistics)

                                                                                        OR/ AND
                                                                                                                          Decision of the                Divergence Appeal by
                                                                                        Automatic Appeal,
                                                                                                                       Administrative Tax              the taxpayer in case of a
                                                                                             in case of a
                                                                                                                         Appeals Council                      success of the
                                                                                        dropping or partly
                                                                                                                      (“CARF”). CARF may                Automatic Appeal) (15
                                                                                          modification of
                                                                                                                      confirm or modify the                       days).
                                                                                        the tax assessment
                                                                                                                     decision of DRJ without             In case the Automatic
                                                                                         (only mandatory for
                                                                                         cancelled tax debts            any time limit (the             Appeal is rejected, the
                                                                                            over BRL 2,5             response may last about 2            tax dispute is over in
                                                                                              million).              years, based on statistics)        benefit of the taxpayer.

        *This Appeal is primarily subject to the verification of its admissibility through evidence of a divergent decision on the same subject previously issued by CARF.

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Tax audits in Brazil – tentative timeline
“Life Cycle” of an Administrative Federal Tax Dispute in Brazil

      July                           August
      15th,                          15th,
      2022                           2022

        Final decision of the Higher Chamber of
        the Administrative Tax Appeals Council                    Payment of tax debts
         (“CSRF”). CSRF may definitely decide                    (including interest and
               in favour of the taxpayer (tax                      penalties) within 30
          assessment is cancelled) or the PGFN                        days from the
            (taxpayer must pay the tax debts),                   notification of the final
        without any time limit (the response may                    decision of CSRF.
              last about 1,5 year, based on statistics)

       1)     There are other types of appeal that may be presented by the taxpayer or the PGFN which, for simplification purposes, were not mentioned in this timeline, such as interlocutory appeal
              and embargoes.

       2)     If, as a result of the administrative tax dispute, the taxpayer must pay the tax debts, it is possible to take the discussion to the courts. But, in this case, the pay to litigate principle
              applies.
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Cash repatriation

              1     WHT on service fees

              2     Cost-sharing agreement

              3     Overview on other cash
                    repatriation fllows

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Cash repatriation

               1    WHT on service fees

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Withholding income tax on cross border remittances related
to service fees - background
  •   The importation of services (both technical and management / administrative) is heavily taxed in Brazil.
      The total tax burden of the transaction (considering all the transactional and WHT) may reach 41% to
      43%. In addition, whenever the transaction is among related parties, TP rules must be considered in
      regarding the deductibility of the services fee.

  •   Nevertheless, on 6 December 2013, the National Treasury’s Attorney General’s Office (PGFN) published
      Opinion No. 2363/2013, through which it formalized the understanding that art. 7 (“Business Profits”)
      of the DTT signed by Brazil could potentially avoid the WHT on cross border remittances related to
      service fees.

  •   The general WHT rate is of 15% (a 25% rate may apply depending on the nature of the remittance).

  •   It is important to note that many DTT signed by Brazil (such as the one signed with Netherlands)
      classifies services fees under article 12 (“Royalties”), and therefore for such treaties no relief should be
      possible for the WHT.

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Withholding income tax on cross border remittances related
to service fees – treaty application

Non treaty country *                             Treaty country *     *

                              Service                                        Service
                             Provider                                       Provider       Treaty country
                             Abroad                                         Abroad

Service fee (-) WHT                                     Service fee

Net fee

                               Br Co                                         Br Co

* Or treaty jurisdictions that art. 7 does not     ** Examples of treaty jurisdictions that art. 7
apply to service fees. In any case, FTC            applies to service fees: Japan, France, Austria,
possibility should be considered                   Finland, Sweden
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Withholding income tax on cross border remittances related
to service fees – key considerations

                                 No Brazilian WHT on remittances of service fees

 Main advantages
                     Possibility to recover WHT unduly paid in the past, limited to 5 years (i.e.
                                            WHT paid as from April 2012)

                     Analysis of the nature of the fees and the DTT must be made to assure the
                            possibility of avoiding WHT on remittance (art. 7 X art. 12)

Important remarks

                    Special procedures should be taken to guarantee the remittance without the
                                                 levy of the WHT

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Cash repatriation

               2    Cost-sharing agreement

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Cost-sharing agreement - background

      Historically, arguments that remittances made under cost sharing agreements should be treated as
      reimbursements were not well received by the Brazilian tax authorities and were characterized as service
      remittances instead. With the publication of favorable tax rulings and the list of criteria to be observed, the
      scenario has improved.

      •   No mark-up should be considered in the structure;

      •   Only back office costs are allowed;

      •   Third party costs (services contracted from third parties) should not be considered as cost sharing;

      •   The cost should not relate to the entity’s core business;

      •   Apportionment criteria should be objective and reasonable;

      •   An identifiable benefit should be obtained by the Brazilian company in relation to the cost being charged;

      •   Proper supporting documentation is mandatory.

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Cost sharing Vs. Service charge

      Cost Sharing                        Service fee

               Company A                           Company A

                           Cost sharing                         Service tax
                           IOF 0,38%                            burden
                                                                41%/43%

               Company B                            Company B

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Cost-sharing agreement - key considerations

                       Substantial reduction of transaction taxes on a cost sharing
      Main advantage
                         agreement (limited to taxation of financial operations
                                            (IOF) of 0.38%)

                            Compliance requirements give high scrutiny to the
                          transaction. i.e: Integrated System of Foreign Service
                                   Trade (“SISCOSERV”) registration

        Important      Conflicting jurisprudence and administrative guidance on
         remarks
                                 the issue. May lead to tax assessments

                         Attention to the implementation in order to guarantee
                         proper compliance with legislation and jurisprudence
                                               guideline

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Cash repatriation

              3     Overview on other cash
                    repatriation fllows

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Dividends

                                                                        Foreign country

  •   Up to now, 0% withholding tax on dividends when
      remitted to (Brazilian and non-resident) shareholders.
  •   Dividend remittances to a foreign beneficiary are
      subject to IOF at 0%.
                                                                                          dividends
                                                               WHT 0%
                                                               IOF 0%

  In case of French parent company, tax costs on dividend:
              Between 0,3443% to 1,7% in FY17
                            (1%/5% x 34,43%)

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Interest on equity

 •    Deductible at the level of the distributing entity, no
                                                                                 taxable
      IOF applies (O%), but subject to 15% withholding
      tax (or 25% if the beneficiary is located in a tax haven
      jurisdiction).
 •    In application of the double tax treaty concluded                              Interest
      between France and Brazil, the French company can                              on equity
                                                                       WHT 15%
      be granted a tax credit of 20%, provided the
      taxpayer can demonstrate that a tax has been paid in
      Brazil.
 •    Fully taxable in France at the level of the receiving
      company in application of the anti-hybrid rules.                           deductible

      In case of French parent company, tax saving on INE:
                          4,57% in FY17
                  (In Brazil: tax saving 34% less WHT expense of 15%
                        In France: 34,43% less 20% tax credit)

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Capital reductions

 •    Provided that the total amount of the capital reduction
      is registered with the Brazilian Central Bank, it will
      only be subject to IOF at 0,38%.
 •    No WHT.
                                                                Capital
                                                                reduction
                                                                 IOF (0,38%)

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Capital gains – new tax rate for residents individuals and
    non-resident corporate and individual investors

•     On 16 March 2016, the Provisional Measure 692/2015 was converted into Law 13.259/2016.

•     Pursuant to Law 13.259/2016, capital gains earned by individuals arising on the alienation of Brazilian assets
      and rights of any nature are subject to income tax at the rates below (before PM 692/2015, a flat rate of 15%
      applied regardless of the amount of the capital gain):

              •   15% on the portion of the gain not exceeding BRL 5 million;
              •   17.5% on the portion of the gain exceeding BRL 5 million and not passing BRL 10 million;
              •   20% on the portion of the gain exceeding BRL 10 million and not passing BRL 30 million; and
              •   22.5% on the portion of the gain exceeding BRL 30 million.

•     Entities under the actual, presumed and arbitrary profit regimes are not subject to these rules (being the key
      methods of calculating income tax for Brazilian entities).

•     Currently, the Brazilian tax legislation provides that non-residents should be subject to the same rules
      as Brazilian individuals. Note that a 25% tax rate still applies if the gains are derived by a resident of a tax
      haven.

•     The Brazilian Federal Revenue Authorities (RFB) published the Interpretative Declaratory Act 3/ 2016
      providing their position that these progressive rates are applicable as from 1 January 2017.

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Q&A
      Cost-sharing agreement

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Appendices – key aspects of the
      brazilian tax system

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Key aspects of the Brazilian tax system
      Income tax

      Headline tax rate: 34%
      •25% income tax (15% CIT + 10% surcharge for income over BRL 240,000)
      •9% social contribution tax

      Standard income tax calculation method (“Lucro Real” ) :
      •General income tax: gross income less applicable deductions
      •Deductibility standards/restrictions:
         -   Ordinary and necessary deductions
         -   Royalties limited to 1% (trademarks) or 5% (technical assistance / other types of IP) of net
             sales revenues.
      •The concept of tax grouping is not applicable for income tax purposes
      •Losses can be carried forward indefinitely but only 30% of yearly profits can be offset against
      previous losses.

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Key aspects of the Brazilian tax system
      Income tax

      •   Thin capitalization rules: 2:1 debt-to-equity ratio (general) or 0,3:1 debt-to-equity ratio (tax
          haven or beneficial tax regime).
      •   Tax on financial operations (IOF) 0f 0,38% in contributions of capital from and into the
          country.
      •   Transfer pricing regulation does not follow OECD rules.

      Specific income tax mechanism – Presumed profit method (“Lucro Presumido”) :
      •   Revenues under BRL 78 millions (EUR ~25 millions)
      •   Tax effective rate varies from ~ 3% to 11% and the basis of calculation is the gross revenue of
          the company.
                                                     Services                    Products
                                                                            (production/retail)

                 Gross revenues                         100                         100

                 Presumed profit margin %              32%                9,06% (average IR + CS)
                 Presumed taxable income                32                         9,06

                 Brazilian income tax rate             34%                         34%

                 Brazilian income tax                  10,88                       3,08
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Key aspects of the Brazilian tax system
      Cross border payments

      •   Income tax withholding on cross-border payments (royalties, services, capital gains, interest):
          -   15% for most payment types.
          -   25% for payments to blacklisted tax havens.
          -   Reduction of the 15% national rate in application of the France-Brazil double tax treaty when
              payments are made to France for:
                  •   Licensing fees for the use of intellectual property rights and softwares (10%) and
                  •   Service fees (0%) - special procedures should be taken to guarantee the remittance
                      without the levy of the WHT.

      •   Tax haven rules: Blacklist (65 jurisdictions) v. gray list (8 types of entities).

      •   Significant indirect taxes on cross-border royalty / technical assistance payments, which can
          generate a 25% extra tax cost on such transactions.

      •   In case of general payments abroad, the currency conversion of Brazilian Real into USD or EUR is
          subject to IOF at a 1,1% rate (0,38% previously).

      •   At the time being, dividends are subject to 0% withholding tax when remitted to shareholders.
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Key aspects of the Brazilian tax system
      Transaction taxes

            Taxes charged at three different levels – Federal, State and Municipal

                Transaction taxes        Jurisdictions              Rates

                      ICMS                   State                   18%

                   PIS/COFINS               Federal                 9,25%

                       IPI                  Federal             Average of 10%

                       ISS                 Municipal                 5%

                    Import tax              Federal             Average of 10%

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Gabriel Oliva Buratto
PwC | Senior Tax Manager on Secondment - ITS -
Brazilian Tax Desk
Tel: +31 88 792 6344 | Mobile: +31 6 1055 8716
gabriel.oliva.buratto@nl.pwc.com
PricewaterhouseCoopers Belastingadviseurs N.V.
(KvK 34180284)
Fascinatio Boulevard 350 | 3065 WB | P.O. Box
8800 | 3009 AV | Rotterdam, the Netherlands

Alice de Massiac
Brazilian Tax Desk
Associée - Partner
Avocat, Barreau des Hauts-de-Seine
PwC Société d’Avocats
Crystal Park – 61, rue de Villiers – 92208 Neuilly-
sur-Seine Cedex – France
T : +33 (0) 1 56 57 41 15 | P : +33 (0) 6 89 33 10 71
alice.de.massiac@pwcavocats.com
www.pwcavocats.com

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