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Brazil: Initial BEPS guidance on dispute resolution; CbC consultation

Brazil: Initial BEPS guidance on dispute resolution

Guidance published in Brazil addresses dispute resolution standards pursuant to the base erosion and profit shifting (BEPS) project.


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Normative Ruling (NR) 1.669/2016 (published 10 November 2016) aims to regulate dispute resolutions under Brazil’s network of international tax treaties and conventions for the avoidance of double taxation, in accordance with BEPS Action 14 (making dispute resolution mechanisms more effective).  

The main aspects under NR 1.669/2016 include the following:

  • All taxpayers will be allowed to open a consultation process when they identify tax measures that results in double taxation.
  • When the resolved dispute results in a tax credit, the taxpayer will request the refund through a specific administrative procedure.
  • The tax administration will issue an implementation order that validates the resolution (even if the resolution resolves only part of the dispute).
  • The implementation of the resolution must be preceded by the acquiescence of the parties involved as well as an agreement to withdraw any pending appeals or lawsuits related to the disputed subject.

Consultation on country-by-country (CbC) reporting

Brazil’s federal revenue service announced a public consultation or comment period regarding the implementation of the country-by-country (CbC) reporting requirements in Brazil. The CbC report will be mandatory as from 2017, and will cover the transactions and business operations undertaken during calendar year 2016, for Brazilian multinational companies with consolidated revenue above BRL 2.26 billion or € 750 million.  The due date for the CbC report will follow the income tax return (ECF) calendar (currently 31 July after the end of the calendar year). The comment period will be open to taxpayer’s suggestions on the federal revenue’s website until 21 November 2016.


For more information, contact a tax professional in Brazil with KPMG’s Global Transfer Pricing Services practice:

Marienne Coutinho | +55 11 3940 3182 |

Eliete Ribeiro | +55 11 3940 3288 |

Carlos Toro | +55 11 3940 6569 |

Edson Costa | +55 11 3940 5313 |

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