Private Ruling COSIT 18/2013 (Solução de Consulta Interna COSIT 18/2013), issued by the Federal Revenue Office and published in the Official Gazette of 13 August 2013, addressed the consistency of CFC legislation with the provisions of the tax treaties signed by Brazil.

The Federal Revenue Office examined if the rule set forth in article 74 of Provisional Measure No. 2.158-35, from 24 August 2011 …