The Resource Brazil's 2013 corporate tax reform : policy and controversy aspects

Brazil's 2013 corporate tax reform : policy and controversy aspects

Label
Brazil's 2013 corporate tax reform : policy and controversy aspects
Title
Brazil's 2013 corporate tax reform : policy and controversy aspects
Creator
Subject
Language
eng
Summary
This article examines relevant aspects of the Brazil's 2013 corporate tax reform as well as the numerous amendments that have been proposed in the Brazilian National Congress. The article gives some background and looks at (I) the transitory tax regime; (II) overview of key changes to the recognition of domestic source income; (III) mandatory adoption in 2015 versus elective adoption in 2014; (IV) treatment of dividends and interest on shareholders' equity; (V) inside basis set-up and goodwill; (VI) present value and fair value adjustments in corporate reorganizations; (VII) controlling subaccounts under the new regime; (VIII) amortization of intangibles and R&D incentives; (IX) premium on debentures and capital reserves for incentives; (X) leasing transactions and other capitalized expenditures; (XI) functional currency; (XII) definition of gross revenues for corporate income taxes and PIS/COFINS (PIS - Contribution to the Social Integration Program, and COFINS - Social Contribution on Revenues) and other PIS/COFINS reforms and; (XIII) foreign source income: controlled foreign entities and foreign affiliates, and the taxation of individuals
Citation source
In: Transfer pricing international journal. - London. - Vol. 15 (2014),
http://library.link/vocab/creatorName
Tavares, R.J.S
Geographic coverage
  • South America
  • Latin America
Language note
English
http://library.link/vocab/subjectName
  • tax reform
  • corporate income tax
  • source of income
  • reorganization
  • amortization
  • intangibles
  • tax incentive
  • leasing
  • social security
  • foreign source income
  • CFC
  • transfer pricing
Label
Brazil's 2013 corporate tax reform : policy and controversy aspects
Instantiates
Publication
Label
Brazil's 2013 corporate tax reform : policy and controversy aspects
Publication

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