Keywords: Brazilian Tax Authorities, normative ruling, corporate income tax, transfer pricing rules

On June 18, 2014, Brazilian Tax Authorities enacted Normative Ruling No. 1,474, including certain Swiss companies incorporated as holding company, domiciliary company, auxiliary company, mixed company and administrative company as privileged tax regimes, when the corporate income tax collected by those entities is below 20%.

Companies that are treated as benefiting from privileged tax regimes are subject to Brazilian Transfer Pricing Rules and Thin Capitalization Rules (debt: equity ratio 0.3:1).

Such change eliminates the discussion on whether Switzerland would be maintained in the blacklist of tax haven countries. Up to this moment, the effects of such inclusion had been suspended by the Declaratory Act No. 11/2010, which was revoked by the Normative Ruling No. 1,474.

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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."

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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 discussed herein.