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14.6. RETAEROThe Special Tax Incentive Regime for the Brazilian Aeronautical Industry (Regime Especial deIncentivos Tributários para a Indústria Aeronáutica Brasileira - RETAERO) was instituted byProvisional Measure 472/09, which was then converted into Law 12,249/10. The RETAERO regime isdesigned to stimulate the expansion of the Country ’ s aeronautical sector and the greaternationalization of aircraft. In accordance with this special tax regime the collection of taxes levied onthe sale in the domestic market and importation of parts and equipment and other materials to beemployed in the maintenance and manufacture of aircraft are suspended.Within this scenario, in transactions conducted in the domestic market, the RETAERO regime includesthe suspension of PIS and COFINS levied on the revenue of corporate sellers and of the IPI levied onthe issue from the industrial establishment. In the case of imports, the suspension applies to the IPIand PIS Import and COFINS Import.14.7. RECOPAThe Special Tax Regime for Construction, Expansion, Renovation or Modernization of FootballStadiums (Regime Especial de Tributação para Construção, Ampliação, Reforma ou Modernização deEstádios de Futebol – RECOPA) was established by Law 12,350/10 to create tax incentivesspecifically related to the stadiums that will hold the games in the 2013 Confederations Cup and 2014World Cup.The RECOPA regime grants tax incentives related to construction work performed in connection withthe above-mentioned stadiums, suspending the collection of:a) Social contributions (PIS and COFINS) levied on the revenues of the corporate seller, arising from:(i) the sale of new machines, apparatus, instruments and equipment purchased by a legal entity that isa RECOPA beneficiary for use or incorporation into the construction work; (ii) the sale of buildingmaterials purchased by a legal entity that is a RECOPA beneficiary for use or incorporation into theconstruction work; (iii) the provision of services by a legal entity incorporated in Brazil to a legal entitythat is a RECOPA beneficiary, when the services are related to the construction work; and (iv) theleasing of machines, apparatus, instruments and equipment for use in the construction work, when thelessee is a legal entity that is a RECOPA beneficiary;b) Industrialized Products Tax (IPI) levied upon the exit from the industrial plant or other establishmenttreated for tax purposes as an industrial plant , when the products are purchased domestically;89

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