Brazil enacts new rules impacting dividend withholding, interest deductions, goodwill amortization and CFCs


The Brazilian government on May 14, 2014 enacted Law No. 12.973/2014, converting into law Provisional Measure 627/2013 (PM 627).

The key provisions of the enacted law are the revocation of the Transitional Tax Regime (RTT) and new rules regarding the treatment of dividends, interest on
net equity (INE), amortization of goodwill, and controlled foreign corporations (CFCs).

The new law will take effect January 1, 2015, but taxpayers may elect to apply it effective January 1, 2014. This election is, if made, irrevocable.


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