On September 14, 2016, Normative Ruling No. 1,658/2016 was
published. The Ruling included an updated list of countries
and premises with favorable taxation and privileged tax regimes
related to Normative Instruction No. 1,037/2010.
Normative Ruling No. 1,658/2016 included a list of countries and
premises with favorable taxation. The list included (i) Curacao,
(ii) Ireland and (iii) Saint-Martin Island; and excluded (i)
Netherlands Antilles and (ii) St. Kitts and Nevis. Additionally,
companies incorporated in the Austrian Republic as holding
companies were included in the list of privileged tax regimes.
The aforementioned Normative Ruling also defines a holding as an
entity that performs economic activities for the purposes of
recognition of privileged tax regimes and possesses operational
capacity corresponding to its business activities in the country
where it is located, which can be proven by (i) the
existence of a sufficient quantity of qualified employees and
(ii) physical installations adequate for the performance
of management for the purpose of decision-making related to its
activities in order to earn incomes derived from assets owned or
from the distribution of profits and capital gain in the management
of corporate equities.
Section 3 of the Normative Ruling established that the new rules
would enter into force on the date in which the Normative Ruling
was published, but would only become effective after October 1,
Founded in 2001, Tauil & Chequer Advogados is a full
service law firm with approximately 90 lawyers and offices in Rio
de Janeiro, São Paulo and Vitória. T&C represents
local and international businesses on their domestic and
cross-border activities and offers clients the full range of legal
services including: corporate and M&A; debt and equity capital
markets; banking and finance; employment and benefits;
environmental; intellectual property; litigation and dispute
resolution; restructuring, bankruptcy and insolvency; tax; and real
estate. The firm has a particularly strong and longstanding
presence in the energy, oil and gas and infrastructure industries
as well as with pension and investment funds. In December 2009,
T&C entered into an agreement to operate in association with
Mayer Brown LLP and become "Tauil & Chequer Advogados in
association with Mayer Brown LLP."
This article provides information and comments on legal
issues and developments of interest. The foregoing is not a
comprehensive treatment of the subject matter covered and is not
intended to provide legal advice. Readers should seek specific
legal advice before taking any action with respect to the matters
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