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How do you rate your relationship with your CFO

Very good, they understand TP requirements well enough
7%
Good but there's room for improvement
29%
Good but TP is not their main concern
51%
They do not understand the requirements of the TP department
12%


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Brazilian thin capitalisation rules after new regulations

July 26, 2011

Thin capitalisation rules were introduced in Brazil by Executive Measure 472/09, approved by Law 12249/10, and regulated by the Federal Revenue Service Normative Instruction 1154/11 (IN RFB 1154).

Fabíola Costa Girão and Andrea de O. Ramos Puppi of Machado and Associates discuss.

Pursuant to these rules, Brazilian legal entities must comply with certain debt/equity ratios to be able to deduct interest paid, or credited, to related parties, residents in tax havens or non-residents benefitting from preferred tax regimes, when calculating their corporate income tax (CIT) and social contribution on net profits (SCNP).

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