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Brazil Modifies the Tax Treatment of Investment Subsidies

26 September 2023

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Approved Changes

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Brazil

Brazil has published Provisional Measure 1.185 of 31 August 2023 in the Official Gazette, which modifies the tax treatment of investment subsidies for the implementation or expansion of economic enterprises. The Provisional Measure repeals the exclusion of investment subsidies from the tax base for Corporate Income Tax (IRPJ) and Social Contribution on Net Income (CSLL), as well as the exemption of investment subsidies from the Contribution for the Social Integration Program (PIS) and the Contribution for the Financing of Social Security (COFINS). As such, investment subsidies will essentially be taxable. However, the Provisional Measure also introduces a new tax credit...