Pursuant to Normative Instruction No. 1,634/2016, as amended and currently in force, the deadline for Brazilian and foreign legal entities enrolled with the Corporate Taxpayer Registry of the Ministry of Finance (CNPJ/MF) before July 1st, 2017, to inform to the Brazilian Federal Revenue their respective final beneficial owners will expire on December 31, 2018. Legal entities enrolled with the CNPJ/MF after July 1st, 2017, or those that were enrolled before that date but that approve changes to their CNPJ/MF registration before December 31, 2018, must observe specific deadlines set forth in the Normative Instruction, as follows:
- Brazilian and foreign legal entities enrolled with the CNPJ/MF before July 1st, 2017, must inform their final beneficial owners to the Brazilian Federal Revenue until the earlier of: (i) the date of the first change made to the CNPJ after July 1st, 2017; or (ii) December 31, 2018; and
- Brazilian and foreign legal entities enrolled with the CNPJ/MF after July 1st, 2017, must inform their final beneficial owners to the Brazilian Federal Revenue within 90 days, subject to an additional 90-day extension, counted as of the enrolment with the CNPJ.
We remain at your entire disposal to address any and all queries on this subject, to assist with the provision of information to the Brazilian Federal Revenue, as well as to analyze specific cases in light of these rules.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
