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Brazil: The RFB has issued IN RFB No. 2184/2024 regulating the thesis transaction regarding the Investment Subsidies Taxation

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In brief

On 3 April 2024, the Federal Revenue of Brazil (RFB) issued Normative Instruction No. 2184/2024, which regulates the tax transaction provided in Article 14 of Law 14789/2023. This transaction aims to encourage companies to pay IRPJ and CSLL (corporate income taxes), resulting from the exclusion of investment subsidies made in disagreement with Article 30 of Law No. 12973 of 13 May 2014, provided that they have not been subject to assessment.

The deadline for joining the program is as follows:

  1. From 10 April 2024 to 30 April 2024 for calculation periods up to 31 December 2022
  2. From 10 April 2024 to 31 July 2024 for calculation periods relating to 2023

The transaction for debts registered as active debts of the RFB, provided in Article 13 of Law 14789/23, has not yet been regulated.

In depth

The main aspects of the program are:

This newsletter is merely a general review of the subjects covered and does not constitute legal opinion or advice.

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Maria Rita Ferragut joined the Firm in 2019. With 25 years of experience, she is the lead partner of the Tax Law group, acting with a focus on Tax Litigation, at the federal, state and municipal levels.
*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

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Rafael Gregorin joined the Firm in 2002 and became partner in 2018. He integrates the tax practice group, with focus on litigation. Mr. Gregorin has a wide breadth of experience in tax and customs litigation, representing clients in disputes involving federal, state and municipal taxes.
*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

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Telírio Saraiva is specialist in tax consultancy and federal tax litigation, having started his career in an accounting audit company – “Big Four”. He has extensive experience with corporate restructuring projects, tax audits, legal opinions, due diligence, tax benefits review, tax planning involving legal and accounting issues, strategic administrative tax litigation and wealth management.
*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

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