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

Resource Information

The work Brazil's 2013 corporate tax reform : policy and controversy aspects represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

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

Creator

• Tavares, R.J.S

Subject

• amortization
• corporate income tax
• foreign source income
• intangibles
• leasing
• CFC
• social security
• source of income
• tax incentive
• tax reform
• transfer pricing
• reorganization

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),

Geographic coverage

• South America
• Latin America

Language note

English