The document summarizes Brazil's complex tax system for foreign investors. It outlines the various taxes imposed at the federal, state, and municipal levels on wealth, income, consumption, payroll, and imports. Major issues include the system's complexity with potential double taxation and conflicts between authorities. Cumulative taxes on consumption and high taxes on labor are also concerns. The document provides an overview to help foreign investors understand and adapt to Brazil's tax laws and systems.

1. www.mouratavares.adv.br
www.mouratavares.adv.br

2. LEGISLATION
税收法
How foreign investors can
adapt to Brazilian systems:
overview of taxation,
technology and labor
www.mouratavares.adv.br

3. Brazilian Tax System
• Federal taxes
• State´s taxes
• City´s taxes
www.mouratavares.adv.br

4. Brazilian Tax System
Wealth levied by taxes:
Ownership:
a) real state: farm lands and residential
real state
b) automobile ownership
www.mouratavares.adv.br

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
www.mouratavares.adv.br

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
www.mouratavares.adv.br

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
www.mouratavares.adv.br

8. Brazilian Tax System
Wealth levied by taxes:
Imports:
• Import tax
• Manufactured products tax (IPI)
• Social contributions on imports
• State tax
www.mouratavares.adv.br

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
www.mouratavares.adv.br

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
www.mouratavares.adv.br

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
www.mouratavares.adv.br

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
www.mouratavares.adv.br

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
www.mouratavares.adv.br

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
www.mouratavares.adv.br

15. Brazilian Tax System – Major tax
issues concerning for foreign investors
d) Transfer pricing rules
e) Non-regular state´s tax benefits
www.mouratavares.adv.br

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
www.mouratavares.adv.br

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
www.mouratavares.adv.br

18. THANK YOU
• Ph.D and Master Degree in Tax Law
Senior Partner at
www.mouratavares.adv.br

19. www.mouratavares.adv.br

20. www.mouratavares.adv.br