Wednesday, 22 February 2017

Brazilian Federal Revenue Office issues final regulations on country-by-country reporting

On December 29, 2016, the Receita Federal do Brasil (RFB), or Brazilian Tax Authorities, issued final regulations — the Normative Instruction RFB 1681/2016 (IN 1681) — that require annual country-by-country (CbC) reporting for Brazilian entities that are part of Multinational Enterprise (MNE) groups.   IN 1681 requires that the controlling entity (Ultimate Parent Entity) of a Brazilian MNE group file a CbC report with the RFB, if the consolidated revenue for the fiscal year immediately preceding the fiscal year to which the CbC report refers (Reporting Fiscal Year) is equal to or greater than R$2,260 million.

Under certain circumstances, Brazilian constituent entities of a non-Brazilian MNE group also may be required to file a CbC report with the RFB, if the consolidated revenue of that non-Brazilian MNE group is equal to or greater than EUR 750 million (or the equivalent amount on January 31, 2015 in the currency of its ultimate parent entity).  The CbC report requirements will be satisfied by submitting a new reporting form, Form W, along with the Brazilian Income Tax Return (ECF).  The first Form W must be submitted by the end of July 2017, for the reporting fiscal year of 2016. 

Source & more info: PwC