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5.4. Construction RightOwners may erect constructions on their land as they deem convenient, respecting the right ofneighbors and administrative regulations. The neighborhood right is regulated in the Civil Code. Theadministrative regulations (construction rules and zoning restrictions) are mainly set forth in municipallaws. Special attention should be paid with respect to the location and authorization for theestablishment of manufacturing plants, which require the approval of the zoning and pollution controlagencies.6. TAX SYSTEM6.1. Main Federal Taxes6.1.1. Income TaxCorporate entities taxed by Actual Taxable Income may determine their income on the basis of theannual balance sheet at 31 December of each year or by quarterly trial balance sheets (arts. 220 and221 of the Income Tax Regulation approved by Decree 3,000 of 26 March 1999 – RIR).Corporate entities that have profits, earnings and capital gains from abroad, are obliged to determineActual Taxable Income (art. 246, III and 394 of the RIR).Income tax is levied at the rate of 15% on the Actual Taxable Income calculated annually (annualActual Taxable Income) or quarterly (quarterly Actual Taxable Income) by corporate entities, inaccordance with their accounting records, prepared pursuant to the commercial and tax laws (art. 541of the RIR). .Under specific circumstances, the tax administration may arbitrate the income amount (art. 530 of theRIR); the applicable rate on taxable income for these cases is also 15%, with due regard to thecomments made further on relating to the tax base of the tax.Corporate entities with partners or shareholders resident or domiciled abroad may calculate incometax by Presumed Income, providing that total income in the previous calendar year did not exceed theR$ 78 million limit, equivalent to approximately US$ 33 million, or R$ 4.65 million, equivalent toapproximately US$ 2.75 million, multiplied by the number of months of activity in the precedingcalendar year, when less than 12 months (art. 13 of Law 9,718 of 27 November 1998 with the wordingintroduced by art. 7º of Law 12,814, of 16 May 2013).31

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