On 21 December 2015, the Brazilian Revenue Service published Executive Declaratory Act No. 3/2015, which repeals the exclusion of Dutch holding companies without sufficient economic substance from Brazil's grey list. Dutch holding companies without sufficient economic substance were originally included in the 2010 Brazilian grey list, but subsequently excluded following a request by the Dutch government to review the inclusion. With the repeal of that exclusion, a number of tax issues that apply for grey-listed jurisdictions/regimes are triggered, including CFC, thin capitalization and transfer pricing rules, non-deductibility of certain expenses, and increased withholding taxes. According to Receita Federal, the repeal...