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Brazil: Tax authority’s focus on ultimate beneficial owners

Brazil: Focus on ultimate beneficial owners

Brazil’s tax authority (Receita Federal) announced an “annual inspection plan” for 2019 that focuses on identifying ultimate beneficial owners that use offshore structures for purposes of obtaining tax benefits.


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The tax authority’s action generally follows the global standard set by the Organisation for Economic Cooperation and Development (OECD) with respect to tax information exchange agreements. Since 2016, Brazil’s tax authority has had in place rules for identifying ultimate beneficial owners—rules that must be observed by investment fund managers and administrators.

Under the annual inspection plan for 2019, the tax authority is requiring administrators to provide certain essential investor data—such as the names of the ultimate beneficial owner of an investment, their nationality, and the amounts remitted abroad and amounts of tax levied on these distributions.

Read an August 2019 report (Portuguese) prepared by the KPMG member firm in Brazil

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