Brazilian Taxes. Guido Vinci Veirano & Advogados Associados March 2002

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1 Brazilian Taxes Guido Vinci Veirano & Advogados Associados March 2002

2 Introduction - Legal Standards Federal Constitution of 1988 National Tax Code of 1966 ("CTN") Constitution: establishes the taxing power and limitations of each member of the Republic (Federal, State and Municipalities). CTN: establishes the general concepts of taxation, exercise of taxing power, elements of the tax obligation (taxable event - tax basis - taxpayer). Complementary Law 104/01 amended, recently, some articles of the CTN,such as article 116, which deals with the taxable event dissimulation.

3 Taxes and contributions are created by Law. Provisional Measures issued by the President are widely used to create and alter Federal taxes (this issue is still controversial) "Annuality" concept applies, with exceptions (IPI, IOF import and export taxes); Contributions - 90 days grace period.

4 Taxation Charges made by the three members of the Republic: Federal, States and Municipalities. Life Cycle of Taxation: Imports Import Tax (II), Excise Tax (IPI), State VAT (ICMS). Pre-Operation IPI, ICMS, Municipal Service Tax (ISS), Banking Tax (CPMF), Payroll Contributions, CIDE - Technology, signature bonus, rentals.

5 Transactions IPI, ICMS, ISS, CPMF as well as Tax on Financial Operations (IOF), CIDE - Technology, CIDE - Fuel, PIS/COFINS gross revenue contributions, royalties, special participation. Profits Income Tax and Social Contribution on Profits. Repatriation Withholding Income Tax (IRRF) and IOF.

6 Non Resident Taxation IRRF charged on remittances abroad by Brazilian source for items such as interest on loans, interest on equity, services, rental of assets, royalties, etc. Applicable rate varies according to item - 0%, 15%, 25% Dividends are tax exempt, even if paid to tax haven. Charter of vessels (eg FPSO's or Seismic vessels) qualify for zero rate. Exception when the beneficiary is located in a "tax haven. In this case IRRF rate is 25%.

7 "Tax haven" rule may impact other types of payments, such as interest on loans and on equity. Double taxation treaty network Based on the OECD model; Includes Canada, Italy, Spain, Japan, Norway, Netherlands; Currently no tax treaty with USA or United Kingdom (UK possibly to be negotiated). The IOF is another tax charged on exchange transactions (inflow or outflow). Currently, the IOF tax rate is reduced to zero for most transactions.

8 Resident Taxation Tax on Profits: Income tax and Social Contribution on Profits. Currently 34% overall on Brazilian GAAP adjusted by additions and authorized exclusions (33% from January 2003 onwards) Taxable period may be yearly or quarterly, the first with anticipations paid monthly on either the real or estimated profit (the last based on a percentage of gross revenues - 8% for industries) Taxpayers with a total revenue up to R$ 24 million may elect the "estimated profit"

9 No consolidation or group relief available for tax purposes. Local intercompany loans attract withholding tax (20%) and IOF. Tax losses may be carried forward indefinitely, but limited to 30% of future taxable income. Exchange gains or losses may be taxed or deducted on an accrual basis or cash basis, at taxpayer s election. No official index restates the local GAAP accounts (i.e. no inflation accounting).

10 Treatment of exploration costs: capital or expenses? Immediate expense treatment for all costs under Article 416 of Income Tax Code: not applicable under Brazilian GAAP. Depreciation rates provided for in Normative Instruction 162/98. Capital goods shall be capitalized and depreciated.

11 Depreciation terms vary from 5 to 20 years (generally 10 years for equipment and 20 for ships) Accelerated depreciation available based on number of working shifts. Facilities operated 16 hours per day may be depreciated at 1.5 times ordinary rate. 24 hours per day = twice ordinary rate.

12 Signature bonus not 100% deductible at outset; should be amortized over the anticipated life of the Concession Agreement. Exploration expenditures. Generally deferred until start of production, then amortized over life of field. Reserves for future abandonment costs in wells and other costs. Initially non deductible, but deductible when realized.

13 Current year deductions: Royalties; Special Participation; Rental Fees; Landowner Fees; Taxes and contributions (except social contribution on profits); Dry wells (and abandoned wells); Lease payments; Other ordinary business expenses; Brazil also allows for the deduction of an interest on capital, which corresponds to a hybrid of a dividend and interest, since it is payable to shareholders, contingent to book profits, but tax deductible as an interest expense.

14 Taxes on Revenues Social contributions on revenues. PIS - levied on gross revenue (except export revenues) at the rate of 0.65%. COFINS - levied on gross revenue (except export revenues) at the rate of 3.0%. Since February of 1999, the basis for these contributions are the total revenues recorded by the legal entity, including financial & exchange gains. For exchange gains, taxpayers may opt to recognize revenues on either cash or accrual basis.

15 Tax aspects of the Consortium The consortium is a non incorporated joint venture, without any legal existence. The tax legislation in force does not fully regulate the procedures and obligations to be followed and complied by a consortium. There is a lack of clear regulations at the State and Municipal levels, although some States already introduced specific rules.

16 At a Federal level there are some provisions, such as: A consortium is not required to file its own Income Tax Return since it is not a taxpayer. It is allowed to have a CNPJ (Corporate Taxpayer Number), to hire employees, withhold the income tax on their remuneration, and open bank accounts. However, it may also be seen as a mere registration of the consortium for statistical purposes.

17 Taxes on Imports (Resident Tax Basis) Import tax (II) Imposed on CIF value. IPI Excise Tax Imposed on CIF plus II. ICMS Imposed on CIF plus II, IPI and recently the ICMS itself (17% or 18%, depending on State) * AFRMM Imposed on freight costs (25%) * Some assets may qualify under reduced rates

18 The Temporary Admission regime Previously, total tax suspension applied. From 01/99 onwards, for most products immediate payment of II and IPI proportionally to the period of presence in Brazil (some assets still qualify for full tax suspension). Basis = normal tax due x period in Brazil / lifetime of asset. ICMS Council (CONFAZ) also authorized the States to issue Laws applying the same concept ( Convention 58/99 ).

19 Oil & gas assets receive special treatment under the so called REPETRO regime (Decree 3,161/99), already extended until December 31, The REPETRO allows equal treatment for local industry, through the so called "fictitious export" mechanism, although there are controversies regarding the ICMS tax. Companies may also apply the drawback and fulfill its export requirements through the "fictitious export", in which case the asset is automatically admitted in REPETRO. Guarantees for the suspended taxes are also required, but in practice no cash collateral is required.

20 Assets subject to the REPETRO (Normative Instruction 04/01) Exploitation, drilling, production and storage vessels. G&G data acquisition equipment. Generally, drilling and production equipment, including platforms, risers and wellheads. The concessionaire is allowed to use REPETRO assets imported to one block for another establishment in a different block, provided it belongs to the same legal entity. In any event, transfer of beneficiary is feasible. Concessionaire s service providers may share the use of REPETRO assets with other legal entities, provided the original contract does not establish exclusivity rights.

21 State Taxes - ICMS Brazilian Tax System ICMS ICMS - levied on: Movement of goods (other than exports) from industrial or commercial establishments, and recently imports by individuals. Interstate and intermunicipal transportation. Communications. Works like a value-added tax - passed along to final consumer. With regard to the fictitious export applicable to oil & gas products under the REPETRO, some States consider that the ICMS is still due. However, it may be claimed that the fictitious export is an export for all legal purposes.

22 ICMS Rate currently 17% or 18%, depending on state. No ICMS on interstate movement of crude oil or oil products. But there is on natural gas (incl. NGLs) - rate currently 12% to 18%, depending on State. Use of ICMS credits on fixed assets available on a 1/ 48 monthly basis. If fixed asset is transferred prior to the 48 months term, the remaining credits are not available. Maintenance of ICMS tax credits for goods consumed in operations as of January 1, 2003.

23 ISS ISS - tax paid by provider of services of any kind (including services rendered on oil and gas wells) Includes most services for petroleum activities. Deductible for income tax purposes. It is unclear whether the tax can be assessed on services relating to offshore wells, once there are doubts regarding the ability of the municipalities to exercise offshore jurisdiction. Average rate is 5% (municipalities can negotiate lower rates for specified types of services). Currently in discussion whether the ISS is due on the place where the service is rendered or on the company s place of business. The so called ISS at source mechanism is becoming more common.

24 Other IOF Financial transactions. Export Taxes Charged on some products depending on government s foreign trade policies. Currently, tax rate on exports of crude oil is zero. IPI (Excise Tax) Charged on imports and industrialization of assets, at various rates depending on the essentiality of the products. Not applicable to sales of oil or gas.

25 Other CPMF Charged at a 0.38% rate on all debit entries on bank accounts (initially scheduled to end June 2002, but the postponement is already being voted in Congress). CIDE - Technology 10% of all technology, technical services and administrative services payments made abroad, payable by the local recipient of the technology/service. Credit mechanism (100% until December 31, 2003, 70% until December 31, 2008 and 30% until December 31, 2013) applicable for of trademark and patents only. Debates whether double taxation treaties can avoid the 10% CIDE charge.

26 Other CIDE - FUEL (downstream operations) Charged on the importation and commercialization on the internal market of gasoline (and its chains), diesel (and its chains), kerosene, fuel-oil, petroleum liquefied gas (also derived from natural gas and naphtha) and ethyl fuel alcohol. Tax rates vary from product to product (gasoline - R$ 501,10 per m 3 ; Diesel - R$ 157,80 per m 3 ; Kerosene - R$ 25,90 per m 3 ; Airplane Kerosene - R$ 21,40 per m 3 ; Fuel-oil - R$ 11,40 per t; Liquefied Petroleum Gas - R$ 104,60 per t; Ethyl Fuel Oil - R$ 22,54 per m 3 ).

27 Other The taxpayer is entitled to deduct the CIDE paid, from the PIS and COFINS amounts due on the commercialization on the internal market of such products, up to the limit foreseen on the legislation

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