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In order to regulate Resolution 13/2012, the National Public Finance Policy Council (ConselhoNacional de Política Fazendária - CONFAZ) enacted SINIEF rulings 19 and 20, which set out theprocedures and ancillary obligations that taxpayers are required to follow and comply with.Finally, it must be noted that under ICMS Agreement (Convênio) 123/2012, no tax benefit is availableas from 1 January 2013 in relation to interstate transactions involving goods that are subject to the 4%ICMS rate, except: (i) if the tax benefit results in an interstate tax burden that is lower than 4%; and (ii)in case of tax exemption.6.2.2. Inheritance and Gift Tax – (Imposto sobre transmissão causa mortis e doação dequaisquer bens ou direitos – ITCMD)ITCMD is levied on the transfer of property or rights (shares, quotas, local or foreign currency,deposits, etc.) taking place by legal or testate succession, including provisional succession, and bygift.The tax base of the ITCMD is the market value of the property or right transferred, expressed in localcurrency. The generally applicable rate is 4% .6.3. Main Municipal Taxes6.3.1. Service Tax - ISSISS is a tax levied by municipal governments (and the Federal District) on service renderings of anynature specified by complementary law and not included in the list of services subject to ICMS(mentioned in item 6.2.1 above). The ISS is calculated based on the price of the service and the rategenerally ranges between 2% and 5%.Among the services subject to the tax are consulting, technical advisory services, plans anddealerships, among others. At this time each municipality establishes its rates for the services taxed.It is important to mention that several municipalities require the registration of companies located inother Brazilian municipalities that render services to recipients based in within such municipality, onpain of the recipient of the service being required to carry out the withholding and payment of the ISS.ISS is also charged on certain imports of services. Hence, the legal provisions of each Municipalityshould be analyzed for specific cases.47

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