On August 25, Sergio André Rocha was interviewed by Valor Econômico regarding the Interpretative Declaratory Act no. 7/2016. In this Act, Brazil’s Tax Office established that the withholding tax and the CIDE contribution are levied on the capital contribution by non-residents with the transfer of technology for the Brazilian entity. In his words “a capital contribution, with funds or assets, is not equivalent to income earned by a non-resident”.
On November 11, 2016, Sergio André was interviewed by Valor Econômico newspaper. He commented on the new Normative Instruction no. 1669 of 2016, which established rules on the use of mutual agreement procedure to settle tax treaty disputes.
On July 5, Sergio André Rocha spoke with Valor Econômico about tax Ruling no. 84/2016. In this case, Brazil’s Tax Office decided that social contributions on revenues (PIS and COFINS) should be levied on the Interest on Net Equity received by companies that pay these contributions under the so-called cumulative system. In his words, “This is a new interpretation from the tax authorities, which could generate new tax assessments. I believe, however, that there are arguments to dispute their interpretation in this case”.