Publication
Horizon Scanning: Investigations and Enforcement
In this horizon scan, we focus on key developments affecting companies operating in the UK, including in light of the recent change in UK government.
Global | Publication | September 2016
On 14 September 2016, the Brazilian tax authorities published the Normative Instruction (NI) Nr. 1,658 dated 13 September 2016 in the Official Journal of Brazilian Federal Executive. This NI amends Brazilian Tax Haven List that was first published in 2010. The changes adversely impacts the tax characterization of, amongst others, Irish leasing transactions and Austrian holding companies as of 1 October 2016. These changes are likely to impact multinational enterprises (MNEs) that invest in, or do business with Brazil.
The changes are likely to impact multinational enterprises (MNEs) that do business with Brazil as of 1 October 2016, amongst other in the following sectors:
The above is a selection of examples of impacted structures. However, this is not meant to be a complete overview. For more information on reviewing structures and solving potential exposures you can contact us.
The newly published NI 1,658/16 amends both the Blacklist and the Greylist as follows:
The changes are likely to impact multinational enterprises (MNEs) that do business with Brazil as of 1 October 2016, amongst other in the following sectors:
The above is a selection of examples of impacted structures. However, this is not meant to be a complete overview. For more information on reviewing structures and solving potential exposures you can contact us.
Publication
In this horizon scan, we focus on key developments affecting companies operating in the UK, including in light of the recent change in UK government.
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