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6.4. Summary of the Tax Burden on Corporate Entity Profits and Labor and Social SecurityCharges of Companies6.4.1. Tax Burden on ProfitsIn summary, the tax burden incurred on company profits, up to their final distribution to partners orshareholders abroad, amounts to approximately 34% (25% as IRPJ and 9% as CSLL).Specifically in the case of the payment of Interest on Owners‟ Equity (Juros sobre Capital Próprio –“JCP”) Withholding Income Tax (IRRF) will be levied at the rate of 15% upon payment to the partners.However, these amounts paid are deductible for the purposes of Corporate Income Tax (IRPJ) andSocial Contribution on Net Income (CSLL), which reduces the tax burden of corporate entities to 19%with respect to the amounts paid as Interest on Owners‟ Equity.6.4.2. Labor and Social Security ChargesThese charges, including employee labor rights, amount to an average of approximately 100% of thepayroll amount.6.5. A Summary of the Tax Burden on Service ImportsWhen involving the importation of services – but not those subject to ICMS – , this transaction will begenerally subject to the levy of ISS, IRRF, PIS, COFINS and CIDE-Technology and IOF, totalingapproximately 50% of the service amount.7. LABOR LAW AND SOCIAL SECURITYThe Consolidation of Labor Laws (Consolidação das Leis de Trabalho - CLT) is the main set of rulesthat regulates labor relations in Brazil. It contains a number of definitions, principles and rulesdesigned to protect the interests of employees and workers in general.7.1. EmployeeIs a natural person who personally provides services to another person, on a habitual basis and undersubordination, in exchange for remuneration.The following criteria must be observed for the hiring of employees in Brazil:48