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Earnings and capital gains derived from financial investments by individual or institutional investorsresident or domiciled abroad suffer the levy of withholding income tax, at the rate of 15% for fixedincome funds, and at rates of between 10% and 15% for variable income funds (art. 29 of MP 2,158-35/01, art. 16 of MP 2,189-49/01 and art. 68 of RFB IN 1,022/2010).Capital gains received by foreign investors from operations conducted in stock, commodity, futuresand similar exchanges are not subject to the levy of income tax (art. 69 of IN 1,022/2010), with theexception of capital gains from combined operations in the put and call option markets in the stock,commodity and futures exchanges (“box”), in the forward market in the stock, commodity and futuresexchanges, in sales operations with guaranty and without daily adjustments, in the over-the-countermarket, and also in operations with gold (financial asset) outside the exchanges, which are taxed asfixed-income financial investments at the rate of 15% (art. 684 of the RIR).The tax system relating to foreign fixed and variable-income investments, transcribed above, does notapply to investments originating from a country that does not tax income or that taxes it at a rate ofunder 20%, i.e. the “Tax Havens”, which will be subject to the same rules established for personsresident or domiciled in the Country (art. 7 of Law 9,959/00).6.1.1.4. Treaties to Avoid Double TaxationIt is important to mention that Brazil has signed treaties to avoid double taxation of income tax that arecurrently effective, with the following countries: South Africa, Argentina, Austria, Belgium, Canada,Chile, China, Korea, Denmark, Ecuador, Spain, the Philippines, Finland, France, Hungary, India,Israel, Italy, Japan, Luxembourg, Mexico, Norway, Peru, Portugal, the Netherlands (Holland), Sweden,the Czech Republic, Slovakia, Ukraine and Venezuela (the latter only for taxes relating to air transport– Decree 86,354/81) (art. 997 of the RIR).6.1.2. Import Duty on Foreign Products – (Imposto sobre a Importação de ProdutosEstrangeiros - I.I.)As a general rule and unless otherwise provided for by law, products imported into the Brazilianterritory are subject to duties at rates of between 0% and 35% (the latter with regards to automobiles)on the customs value (generally, CIF). However, most taxed products are subject to rates of between10% and 20%. See also paragraph 23.2.35

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