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The 2012 worldwide VAT, GST and sales tax guide

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B RAZIL – BULGARIA 89<br />

• <strong>The</strong> <strong>tax</strong>payer must be qualified through a Permanent Technical<br />

Committee (Comissão Técnica Pemanete, or COTEPE) Act.<br />

Such dispositions must be included in the internal legislation of<br />

each state. This may take some time because the agreement was<br />

signed recently. However, under the law, if states fail to ratify the<br />

ICMS Agreement within 15 days after the agreement is published,<br />

the ratification is tacit, <strong>and</strong> the dispositions in the agreement<br />

become valid.<br />

Special <strong>tax</strong> regime for construction, expansion, renovation or modernization<br />

of football stadiums. In general, the Special Tax<br />

Regime for Construction, Expansion, Reform <strong>and</strong> Modernization<br />

of Football Stadiums (Regime Especial de Tributação para<br />

Construção, Ampliação, Reforma ou Modernização de Estádios<br />

de Futebol, or RECOPA) grants the suspension of IPI, PIS <strong>and</strong><br />

COFINS with respect to domestic <strong>sales</strong> <strong>and</strong> importation of<br />

machinery, devices, instruments <strong>and</strong> new equipment for construction,<br />

expansion, renovation or modernization of stadiums to<br />

be used in the Confederation Cup <strong>and</strong> World Cup official games.<br />

Goods <strong>and</strong> materials imported by RECOPA beneficiary companies<br />

are not subject to Import Tax <strong>and</strong> acquisitions of local <strong>and</strong><br />

foreign services by such companies are not subject to federal<br />

<strong>tax</strong>es.<br />

<strong>The</strong> <strong>tax</strong> benefits apply to projects approved on or before 31<br />

December <strong>2012</strong> except for companies under the National<br />

“Simples” <strong>tax</strong>ation system. <strong>The</strong> benefits can be enjoyed with<br />

respect to acquisitions <strong>and</strong> importations from the date Law No.<br />

12350 was published (21 December 2010) through 30 June 2014.<br />

Only legal entities previously qualified or co-qualified by the<br />

Brazilian Revenue Service can make transactions with RECOPA<br />

support, <strong>and</strong> such qualification may be requested by the holder of<br />

a project previously approved by the Ministry of Sports for construction,<br />

expansion, renovation or modernization of soccer stadiums<br />

with intended use in official matches of the 2013 FIFA<br />

Confederation Cup <strong>and</strong> the 2014 FIFA World Cup. A company<br />

hired by a qualified company to execute activities or provide<br />

goods related to its project may request the co-qualification.<br />

Bulgaria<br />

(Country code 359 )<br />

Sofia GMT +2<br />

Ernst & Young<br />

Business Park Sofia<br />

Building 10, Floor 2<br />

Mladost 4<br />

1766 Sofia<br />

Bulgaria<br />

Indirect <strong>tax</strong> contacts<br />

Trevor Link +359 (2) 817-7100<br />

Email: trevor.link@bg.ey.com

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