The Brazilian Institute of the Environment and Renewable Natural Resources (IBAMA) established a new way of calculating the Environmental Control and Inspection Fee (TCFA) and, as of the first quarter of 2024, the economic size to be declared by subsidiaries will be the economic size of the parent company and the subsidiary jointly, considering the annual gross income of the legal entity as a whole for the basis for calculating this fee.
On 13 March 2024, the Brazilian IRS published Normative Instruction 2.180/24 (“IN 2.180/24”), which provides for the taxation of income earned by individuals resident in Brazil from non-interest-bearing deposits abroad, foreign currency held in kind, financial investments, controlled entities and trusts abroad, as well as the option to update the value of assets and rights abroad.
The long-awaited IN 2.180/24 regulates Law 14,754/23, which was passed on 12 December 2023 and brought important clarifications regarding the taxation by Income Tax of individuals (IRPF) with assets abroad.
On 27 March 2024, Decree No. 281/2024 (“Decree”) was published in the Official Gazette. The Decree extends the deadline for repatriating financial assets of at least 5% of the total value of assets located abroad from 31 March 2024 to 30 April 2024, inclusive.
As a reminder, the applicable personal assets tax rates for assets located abroad will be the same as those applicable to assets located in Argentina if, before 31 March of each year, taxpayers repatriate financial assets of at least 5% of the total value of assets located abroad and if certain additional requirements have been met.
On 19 March 2024, the Public Notice of Special Settlement Agreement No. 1/2024 was published, which provides for the opening of the Zero Litigation Program 2024, a new special settlement agreement for tax debts in administrative litigation within the scope of the IRS of Brazil, the value of which, per litigation, is up to BRL 50,000,000.00. Discounts and payment terms will be determined according to the degree of recoverability of the debts. The deadline for joining the Program is 1 April 2024 to 31 July 2024.
On 3 April 2024, the Federal Revenue of Brazil (RFB) issued Normative Instruction No. 2184/2024, which regulates the tax transaction provided in Article 14 of Law 14789/2023. This transaction aims to encourage companies to pay IRPJ and CSLL (corporate income taxes), resulting from the exclusion of investment subsidies made in disagreement with Article 30 of Law No. 12973 of 13 May 2014, provided that they have not been subject to assessment.
The Entertainment Complex Policy Parliamentary Committee has considered and endorsed the draft Entertainment Complex Bill, B.E. (“Entertainment Complex Bill”), a concept initiated many years ago. The Entertainment Complex Bill aims to facilitate the establishment of entertainment complexes that include casinos. This has been passed to the House of Representatives in March 2024.
Following the end of the UK tax year on 5 April 2024, annual Employment-Related Securities (ERS) returns may now be filed online with HMRC. All companies with open share plan registrations with HMRC are required to submit an annual return, even if it is a nil return (i.e., even if there has been no share plan activity during the 2023 to 2024 tax year). The deadline for submission for the 2023 to 2024 tax year is 6 July 2024.
The Ministry of People’s Power for Science and Technology, through the National Fund for Science, Technology and Innovation (FONACIT), issued Administrative Ruling No. 015-004-2024 on 9 January 2024, which established the procedure and regulations regarding the assessment, self-assessment, payment and monthly return filing of the contributions for science, technology, innovation and their applications.
The National Executive Power issued Decree No. 4924 on 21 February 2024, which exonerates the following from paying the Large Financial Transactions Tax (LFTT): (i) debits that generate the purchase, sale or transfer of securities issued or guaranteed by the Republic or the Central Bank of Venezuela, (ii) debits or withdrawals related to the payment of their capital or interest, and (iii) securities traded in different stock exchanges or the agricultural stock exchange, made in a currency other than the legal tender.
On 6 March 2024, the current government (led by the Conservative Party) announced a number of significant changes to the way in which UK tax resident non-UK domiciled (RND) individuals will be taxed in future. These changes are expected to take effect from 6 April 2025. In this alert we provide a recap of the reforms announced by the current Conservative government, and an overview of the further changes that the Labour Party has said it will introduce if elected.