Cross-border Tax Talks

March 26, 2024

Brazil Tax Reforms: muito complicado!

Doug McHoney (PwC’s International Tax Services Global Leader) is in São Paulo, Brazil for the first Latin American recording of the CBTT with PwC Brazil’s International Tax Leader Dr. Romero Tavares. Doug and Romero discuss what makes Brazil’s tax system so unique – from its transfer pricing rules to its full inclusion regime. They also dive into expected Brazilian tax changes, the many acronyms that make up the indirect tax system, Pillar One, and what effect Pillar Two will have on Brazil’s taxpayers.

Timestamps:

  • 1:35 - What motivated Romero to obtain a PhD in International Tax Policy in Vienna, Austria in the middle of his career?
  • 3:40  -  What is the framework of the Brazilian corporate international tax regime? 
  • 6:00 - What is the Brazilian CFC regime?
  • 9:08 - How has Brazil historically treated Transfer Pricing?
  • 14:15 - When do the new Brazilian Transfer Pricing rules come into effect and how will they affect taxpayers?
  • 19:15 - Any thoughts on the timing of additional Transfer Pricing regulations?
  • 20:40 - Can you provide an overview of the indirect tax system in Brazil?
  • 27:00 - What is on the horizon for Brazilian corporate tax changes?
  • 30:50 - How are Brazilian policymakers thinking about the full inclusion regime for foreign subsidiaries in Brazil and is Pillar Two on the radar? 
  • 35:30 - What are you hearing from Brazil regarding the enactment of Pillar One?
  • 38:30 - How are Brazilian taxpayers preparing for Pillar Two?

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Speakers

Doug McHoney

International Tax Services Global Leader, PwC US

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Romero Tavares

Sócio, PwC Brasil

4004 8000

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Doug McHoney

Doug McHoney

International Tax Services Global Leader, PwC US

Geoff Jacobi

Geoff Jacobi

ITS, Knowledge Management Managing Director, PwC US

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