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2. LEGISLATION
税收法
How foreign investors can
adapt to Brazilian systems:
overview of taxation,
technology and labor
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3. Brazilian Tax System
• Federal taxes
• State´s taxes
• City´s taxes
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4. Brazilian Tax System
Wealth levied by taxes:
Ownership:
a) real state: farm lands and residential
real state
b) automobile ownership
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5. Brazilian Tax System
Wealth levied by taxes:
Income:
• Federal income tax: 15% or 25% on
corporation´s profits;
• Federal income tax on individuals: 7,5% to
27,5% of worker´s revenues
• Social contribution on profits: 9% on
corporation´s profits
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6. Brazilian Tax System
Wealth levied by taxes:
Consumption:
• Federal social contributions (PIS/COFINS): 3,65% or
9,25% (added value system) on sales and services
• Federal added value taxes on manufactured produts
sales (IPI)
• State added value tax (ICMS): various rates on sales
of goods, comunication and transport
• City´s tax on services: 2% to 5% rate on a list of 255
diferent types of services
• Specific contributions on gasoline and other oil
products
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7. Brazilian Tax System
Wealth levied by taxes:
Payroll taxes:
• Social contributions on worker´s salary:
34,8% to 36,8% on every payment done to
employees, except non-remuneration
payments, and 20% to other non-
employee workers
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8. Brazilian Tax System
Wealth levied by taxes:
Imports:
• Import tax
• Manufactured products tax (IPI)
• Social contributions on imports
• State tax
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9. Brazilian Tax System
Small and Middle Size Companies pay
most of the taxes by way of a unified tax
system levied on their revenues
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10. Brazilian Tax System – Major tax
issues concerning for foreign investors
a) Complexity of the system:
• Tax conflits between diferent tax authorities:
even if the Brazilian Constitution prohibit
double taxation over the same wealth –
property, income or consumption, an
operation can be charged by two diferent tax
authorities
• Many forms and subsidiary duties to be
complied with
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11. Brazilian Tax System – Major tax
issues concerning for foreign investors
a) Complexity of the system:
• Tax conflits between diferent tax
authorities: even if the Brazilian
Constitution prohibit double taxation over
the same wealth – property, income or
consumption, an operation can be
charged by two or more diferent tax
authorities: companies may need judicial
resolution
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12. Brazilian Tax System – Major tax
issues concerning for foreign investors
a) Complexity of the system:
• Many forms and accessory duties to be
fullfild
• Eletronic invoice and other information
provided by companies to Federal
government: the necessary assistance of
an accountant office with wide experience
on providing these informations
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13. Brazilian Tax System – Major tax
issues concerning for foreign investors
b) Cumulation on taxes over consumption:
• IPI, State´s value added tax (ICMS), social
contributions on sales (PIS/COFINS)
• Restrictions on credits of non-cumulative
taxes
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14. Brazilian Tax System – Major tax
issues concerning for foreign investors
c) Higher taxation on worker´s
remuneration:
• The recent federal govern attempt to
reduce the tax burden over labour
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15. Brazilian Tax System – Major tax
issues concerning for foreign investors
d) Transfer pricing rules
e) Non-regular state´s tax benefits
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16. Brazilian Tax System – Major tax
issues concerning for foreign investors
f) Payment or credit to investors located in
HK
g) Taxation on income paid or credited to
taxpayers in Mainland China
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17. Brazilian Tax System – Major tax
issues concerning for foreign investors
h) Acquisition of capital goods: tax credits
i) Income tax exemption on profit payments
j) Loan and Currency Exchange tax on loans
and credits received from abroad
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18. THANK YOU
• Ph.D and Master Degree in Tax Law
Senior Partner at
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