José Henrique Longo

[EN] Recently, The National Treasury Attorney's Office (PGFN) and the Revenue Service of Brazil (RFB) launched new tax settlement programs, allowing taxpayers to end disputes with significant discounts.   Among the highlighted programs are the tax settlement for active Union debts with discounts of up to 100% on interest, fines, and charges, the small-value tax settlement for debts up to 60 minimum wages, and the tax settlement for debts guaranteed by insurance or surety bond. All programs have specific adherence deadlines, ranging from June to August 2024, and are available through the REGULARIZE and e-CAC portals.   Read the full text and learn more about Tax Settlement programs, material prepared by Daniela Ribeiro de Andrade and Wellington Oliveira Teixeira: https://lnkd.in/eKf7J8dB   #SperlingAdvogados #PGN #RFB #TaxSettlement

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On May 23rd, FIUS experts unpacked the opportunities and challenges of investing in Brazil. Milton Schivitaro (Tax advisor), Bruno Santo (Tax Advisory Partner), Andrea Tincani (Corporate Law Partner) and Rachel Marques (Corporate Law and M&A) led a discussion on navigating the Brazilian market. A global conversation with participants from 20 countries. Thank you to everyone who joined us! #FinocchioeUstra #Fius #Event #DoingBusinessInBrazil #Investment #Brazil

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The Brazilian #EYITSConference 15th Edition this year was an outstanding record success: from #BEPS2.0 / #Pillar2, #TPOECD, compensatory adjustments and customs impacts, to the #BrazilianTaxReform and Panels on Tech/GenAI, we take fertile discussions to a high-level of Clients in the audience, to whom we do appreciated for the prestige. Gustavo Carmona Sanches moderated a panel with Daniel Loria (Secretariat of the Br Tax Reform Director) and Jason Yen (former American Treasury), providing thought-provoking insights on the international tax policy outlook for Brazil and the US. Well organized by Rita André Martins and Suzana Bicalho Hoefle, that edition also featured on special guests from abroad, our partners: Katherine Pinzón-Romero, Al Paul, and Tim Gunning, who contributed with Marcio Roberto de Oliveira, Ian Craig, and TP team to enhance even more local expertise; Elizabeth Arrendale shared her innovative strategies to Patrick Seixas and Tax Transactions team; Ramon Taboada, Nicolás Brancoli, Abril Rodríguez Esparza, Milton Gonzalez Malla, and Gustavo Scravaglieri, brought different international tax points of view to debate with Priscila Vergueiro, Mariano Manente, Mark Conomy, and Carlos Eduardo Cavalieri. Finally, Giovanni Schiavone and Leandro Cassiano showed some of the most modern tech solutions (e.g. #BEYondTax, #EY.Q, and #EY.Guru), #GenAI tools of which we have been applying to elevate Tax Departments as a modern game changer into companies.

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Following the increasing number of Judicial Recovery in Brazil during past month. National and International credit managers and trade finance professionals must be diligent and cautious regarding to their decisions.

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The new Brazilian transfer pricing rules have been mandatory for seven months now and it is time to consider potential controversy implications come the first audit and how to be prepared. Read our article on some aspects of the new rules taxpayers may want to consider.

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Starting a business in Brazil? Here are the essential public registrations your company needs to operate: 1. CNPJ (Cadastro Nacional de Pessoa Jurídica): The Brazilian equivalent of a Tax ID, this registration with the Receita Federal is the first step in legally establishing your business. 2. State Registration (Inscrição Estadual): Mandatory for companies involved in the sale of goods, this registration with the state’s Finance Department is crucial for managing ICMS (a type of sales tax). 3. Municipal Registration (Inscrição Municipal): Required for service providers, this registration with the local city hall ensures compliance with municipal tax obligations, like the ISS (Service Tax). 4. Commercial Board Registration: This is necessary for formalizing the company's existence, operating rules and structure, including the registration of its bylaws or articles of incorporation. Ensuring these registrations are in place not only makes your business compliant but also builds a solid foundation for growth and success in the Brazilian market. #Brazil #Business #Entrepreneurship #Compliance

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It's no secret that the Brazilian market is as promising as it is daunting. With huge opportunities, major stakeholders, and diverse clients, it is also a very bureaucratic country where networking is of utmost importance. We highly recommend reading V2M's insights on the first steps to setting up businesses in Brazil.

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PAG.LAW PLLC and our associate Felipe Saraiva Carneiro collaborated with Endeavor Brasil's guide on the Offshore Taxation Law (Law 14.754), which discusses impacts for entrepreneurs and investors, as well as the international taxation landscape. Offshore taxation is a global trend. In the past 15 years, most countries have updated their legislation, including the United States, Europe, Colombia, and Chile. Brazil is the most recent case, with Law 14.754 in effect since January. Navigating a volatile and challenging market like Venture Capital has led entrepreneurs to transfer their control abroad increasingly earlier, starting from the seed stages. However, this is a decision with significant impact that needs to be carefully analyzed to avoid legal and economic issues at critical moments in the journey, such as raising growth capital or an exit. Access the complete study: https://lnkd.in/dikNxHmT

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I recently delved into this insightful article titled "Taxation by Analogy in Latin American Jurisprudence" by Larissa Torhacs, and it's a must-read for anyone interested in the nuanced interplay between law and language. The article carefully handpicks and brilliantly connects major precedents in Brazil, Argentina, Colombia, and Mexico and highlights how hermeneutics—the art and science of interpretation—plays a pivotal role in defining whether specific legal provisions apply to situations not listed in the legal text. In the realm of taxation, where clarity and precision are paramount, the use of language not only shapes legal outcomes but also upholds the principles of fairness and equity. Torhacs' exploration into how courts across Latin America handle the delicate issue of taxation by analogy is particularly thought-provoking. The use of analogy in law can be contentious, as it stretches the application of existing legal texts to new, unaddressed scenarios. This practice, while innovative, must tread carefully to maintain the balance between legal intention and the evolving realities of business and technology. What stands out in this discussion is the critical importance of language in legal texts. The choice of words, the structure of sentences, and the interpretive openness of legal language can significantly influence judicial decisions. This article serves as a compelling reminder of why meticulous attention to language is not just a scholarly concern but a practical necessity in law. For legal professionals and scholars alike, Torhacs' work offers valuable insights into how legal frameworks adapt to technological advancements and changing societal norms through the lens of linguistic analysis. A fascinating read that underscores the profound impact of hermeneutics on the development and application of tax law! #LawAndLanguage #LegalInterpretation #TaxLaw #Hermeneutics #JudicialDecisions https://lnkd.in/dYfgHYKF

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Confused about the differences between Simples Nacional, Presumed Profit (Lucro Presumido), and Actual Profit (Lucro Real)? Our latest reel breaks down each tax regime, explaining the benefits and requirements for businesses in Brazil. 📊✨ Whether you're a startup or an established company, choosing the right tax regime is crucial for your financial success. Watch the video to learn more and make informed decisions for your business. Got questions? Drop them in the comments below! 👇 #BusinessInBrazil #TaxRegimes #SimplesNacional #LucroPresumido #LucroReal #Integrance #TaxAdvice

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Challenges and Reflections: The Impact of ADI 5322 on the Brazilian Economy Currently, Brazil faces one of the most challenging moments in its history, with a political and economic environment marked by insecurity and uncertainties. In this context, the recent decision of the Supreme Federal Court (STF) on ADI 5322, which declared unconstitutional sections of Law 13,103/2015 related to road transport, raises important reflections on the country's future. The transportation sector is essential for the entire production chain, being responsible for ensuring the flow of goods and inputs that drive the economy. The declarations of unconstitutionality in ADI 5322 have a direct impact on this sector, generating a series of economic and financial challenges. First of all, the legal uncertainty generated by this decision may hinder investments in the transportation sector, as companies may feel discouraged to make new investments without the guarantee of stability in the rules of the game. This can directly impact the modernization of the country's logistical infrastructure, which is necessary to increase efficiency and competitiveness in our economy. Also, the declarations of unconstitutionality can impact transportation costs, which, in turn, can affect the prices of products for the end consumer. With the increase in transportation costs, companies may have difficulty maintaining their operations and offering competitive prices, which can result in a reduction in economic activity and employment in the country. In this scenario, it is crucial for the government and the private sector to work together to find solutions that promote the sustainable development of the transportation sector and, consequently, the entire economy. It is necessary to find a balance between the need for regulation of the sector and the guarantee of the legal security necessary to attract investments and promote economic growth.

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🚀 We continue our series ‘Navigating Intellectual Property in Brazil: A Guide for U.S. SMEs’. 🇧🇷💼 🌐 Our second post, “Key Considerations for SMEs: Filing Patents in Brazil”, provides a comprehensive guide to entering the Brazilian market and securing patent protection not only as a legal necessity but also as a strategic imperative. 🔗 Dive into the full article here: https://lnkd.in/d6juQ3Z3 🇧🇷 Portuguese version available here: https://lnkd.in/d7qcApDW Stay tuned for more insightful articles in this series! 🤝 📧 For more information, reach out to us at hello@moellerip.com #IntellectualProperty #Brazil #Patents #Trademarks

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