Tax Impacts to Structure Investments in Brazil Debt or Equity. Andrea Bazzo Lauletta November 2012

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1 Tax Impacts to Structure Investments in Brazil Debt or Equity Andrea Bazzo Lauletta November 2012

2 Introduction Brazilian Scenario for Non-Resident Investments Brazil has a specific set of rules for non-resident investments in the country in the Brazilian capital and financial markets as well as private equity and direct investments Foreign exchange mechanisms Regulatory requirements for registration of the investments Tax specific rules Scope of the Tax Analysis Investments in Brazil - although there are some specific tax issues for certain economic sectors, some impacts are analyzed on a general basis Tax issues on structuring Tax issues on financing Tax issues of the business Tax issues on exit 2

3 Introduction General Tax Issues on Income Tax (IT) Non Brazilian residents are subject to IT (i) on income paid by a Brazilian source and (ii) on gain derived from disposal of assets located in Brazil What are assets located in Brazil? How about indirect sale of Brazilian shares? The tax rates varies according to certain characteristics Type of the investment and form of registration of the investment before the Central Bank and Brazilian Securities Commission (CVM): Law no. 4,131/62 and Resolution no. 2,689/00 Nature of the payments: 0%, 15% or 25% Location of the beneficiary: general rates impacted by tax havens or tax treaties 3

4 Investment in Companies Analysis Tax burden of corporate taxation in Brazil of 34% X inversion of the tax burden to abroad Equity Structure Debt Structure (2) Flow of dividends: exemption of IT (2) Flow of interest: IT of 15% 4 (1) Taxation at 34% (1) Deduction of interest expenses = ANALYSIS OF TRANSFER PRICE AND THIN CAPITALIZATION RULES!!!

5 Investment in Companies in Tax Haven s resident or domiciled in places considered by the Brazilian legislation as a favorable tax haven jurisdiction (FTJ) are generally subject to higher rates of IT Discussion on the concept of FTJ Country or place that does not impose income tax or imposes at a maximum rate lower than 20% Extension of concept of privileged tax regime (PTR) No income tax income or income tax at a maximum rate lower than 20% Tax benefits to non-resident: a) without substantial economic activity carried out locally; b) contingent upon no substantial economic activity being carried out locally No income tax or income tax at a maximum rate lower than 20% for income assessed outside its territory Not providing access to information related to shareholding composition, ownership of goods or rights or the economic transactions carried out In our view, PTR rules apply only for transfer price (export and import transactions and loan agreements) and thin capitalization 5

6 Investment in Companies New Structures of Debt Reduction of the IT to 0% on interest Debentures of investment project or infrastructure Law no. 12,431 Several requirements 6

7 Analysis on Exit Taxation of Capital Gains General Rules Capital gains: difference between the sale price and the acquisition cost Sale of assets located in Brazil Acquisition cost in Brazilian currency or foreign currency? IT of 15% FTJ is subject to 25% Exemption of IT in case of sale of shares through the stock exchange by investor registered according to Resolution no. 2,689/00 and not a FTJ 7

8 Structure with FIP What is a FIP? In Brazil, investment funds are not legal entities but condominiums (no legal personality) Taxation of FIP Totally exempt of taxation at the FIP level Gains on any disposal of the investments in the Brazilian corporations are not taxable Income from the investments in the Brazilian corporations are not taxable Portfolio must be made up of shares or other securities that are convertible into shares issued by any listed or closely-held corporations FIP can not have limitadas 8

9 Structure with FIP Requirements for the Tax Benefit of 0% Rate not located in FTJ Each investor does not hold individually or together with related persons, more than 40% of the sum of the shares (Shareholding Test) or receive more than 40% of the total income distributed by the fund (Economic Test) No debt securities of an amount equivalent to more than 5% of its net equity, except if such securities correspond to convertible debentures or subscription bonus Portfolio of at least 90% of shares of Brazilian corporations, debentures that are convertible into shares and subscription bonus 9

10 Structure with FIP 40% Test A B C 30% 31% 39% FIP 10 SA

11 Structure with FIP 40% Test A 100% 100% 100% Vehicle A Vehicle B Vehicle C 30% 31% 39% FIP 11 SA

12 Structure with FIP 40% Test A B C? 30% 31% 39% Feeder Fund 100% 100% 100% Vehicle A Vehicle B Vehicle C 30% 31% 39% FIP 12 SA

13 Comparison of Structures Flow of Dividends Taxation of IT Scenario 1 Scenario 2 Scenario 3 s Dividends: 0% Dividends: 0% Holding Dividends: 0% FIP Dividends: 0% if the Requirements are met or (?) Dividends: 0% 13 Limitada or SA Limitada or SA SA

14 Comparison of Structures Capital Gain Taxation of IT Non FTJ Scenario 1 Buyer IT: 15% Sale of the operational company 2,689 Investment Exchange Market: 0% Private sale and IPO: 15% 14 Limitada or SA Buyer

15 Comparison of Structures Capital Gain Taxation of IT Non FTJ Scenario 2 Buyer Holding Sale of the Holding Sale of the operational company IT: 15% 2,689 Investment Exchange Market: 0% Private sale and IPO: 15% Corporate taxation 34% 15 Limitada or SA Buyer

16 Comparison of Structures Capital Gain Taxation of IT Non FTJ Scenario 3 Buyer Sale or amortization of FIP quotas 0% if the Requirements are met 0% if sale on the Exchange Market 15% if the Requirements are not met FIP Sale of the operational company No taxation 16 Limitada or SA Buyer

17 Tax on Foreign Exchange Transactions (IOF/FX) Main Issues Monetary tool Collection is a secondary focus Rates are modified by decrees No period for adjustment: application of chances are immediate Tax Events Inflow of funds into Brazil Remittances of funds from Brazil Rates Maximum Rate 25% Current Rates Rule: 0,38% Others: 0% or 6% 17

18 IOF/FX Equity Investments Investment in non-public traded company (Law no. 4,131): 0.38% Investment in public traded company (Resolution no. 2,689): 0% Remittances of dividends and interest on capital: 0% Inflow for debt: 6% or 0% (period longer than 2 years) Remittances of interest: 0% Investment in FIP and returns: 0% 18

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