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Brazil Adds Ireland to Black List and Austrian Holding Companies to Grey List

16 September 2016

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Approved Changes

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Brazil-Austria-Curacao-Denmark-Ireland-Netherlands-Sint Maarten

On 13 September 2016, Brazil published Normative Instruction RFB No. 1658/2016 in the Official Gazette, which amends Normative Instruction RFB No. 1037/2010 (list of low tax jurisdictions and privileged tax regimes). The main amendments include: The addition of Curacao, Ireland and Sint Maarten as low tax jurisdictions (black list), and the removal of the Netherlands Antilles; The addition of the Austrian holding company regime as a privileged tax regime (grey list); and The addition of a definition for substantial economic activity in relation to Danish and Dutch holding company regimes (grey listed), which essentially states that a holding company is...