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Clarissa Giannetti Machado

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Clarissa Giannetti Machado Miras joined the Firm in 1999 and became partner in 2007 .
She is the Head of the tax practice group in Brazil and the Head of the Pro-Bono Committee, being a member of the Social Responsibility team of the firm. Her focus is tax consulting on corporate income and other federal taxes. Clarissa has extensive experience in the elaboration and analysis of global transfer pricing analysis and its effects vis-à- vis the local legislation. Clarissa has a wide breadth of experience in the assistance of clients for the development of efficient structures in M&A transactions, local and international restructurings, real estate and financing transactions. She also advises individuals on wealth management matters.
*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

On 13 March 2024, the Brazilian IRS published Normative Instruction 2.180/24 (“IN 2.180/24”), which provides for the taxation of income earned by individuals resident in Brazil from non-interest-bearing deposits abroad, foreign currency held in kind, financial investments, controlled entities and trusts abroad, as well as the option to update the value of assets and rights abroad.
The long-awaited IN 2.180/24 regulates Law 14,754/23, which was passed on 12 December 2023 and brought important clarifications regarding the taxation by Income Tax of individuals (IRPF) with assets abroad.

On 13 March 2024, the Brazilian IRS published Normative Instruction 2.180/24 (“IN 2.180/24”), which provides for the taxation of income earned by individuals resident in Brazil from non-interest-bearing deposits abroad, foreign currency held in kind, financial investments, controlled entities and trusts abroad, as well as the option to update the value of assets and rights abroad.
The long-awaited IN 2.180/24 regulates Law 14,754/23, which was passed on 12 December 2023 and brought important clarifications regarding the taxation by Income Tax of individuals (IRPF) with assets abroad.

On 16 December 2023, the House of Representatives approved the bill of Tax Reform, based on PEC 45 (Constitutional Amendment Bill), in the final round after the Senate’s approval.

The final wording was published on 21 December 2023 (Constitutional Amendment No 132/23).

On 21 September 2023, Law no. 14,689/2023 was enacted as a result of the sanction, with vetoes, by the Vice-President of the No. 2,384/2023, with the purpose of disciplining the proclamation of judgment results in the event of a tie vote within the scope of the Administrative Council of Tax Appeals (CARF), among other measures connected to tax litigation and the transaction in the collection of credits by the Federal Treasury.

On 8 August 2023, the Report of the Provisional Measure No. 1.172 of 2023, that provides new rules for the minimum wage in Brazil, was presented and approved by the Joint Committee in charge of this at the Brazilian Congress.

The Report incorporated the main changes on the taxation rules for individuals investing abroad, previously provided in Provisional Measure 1.171/23, which regulates the taxation of earnings by Brazilian individuals in financial investments, controlled entities and trusts abroad.

In brief After much anticipation, the OECD released the ‘Blueprint’ for their Pillar Two proposal on 12 October as part of its two pillar package to deal with the increasing digitalisation of the economy. The premise behind the Pillar Two proposal is simple, if a state does not exercise their…

In brief The Baker McKenzie Global Tax Team has undertaken an in-depth analysis of the ‘Blueprint’ for the Pillar One proposal to produce a digestible summary of everything you need to know. To read our summary of the Blueprint for Pillar Two please click here. Contents CHAPTER 1 – INTRODUCTION TO…