DT3901 - Double Taxation Relief Manual: Guidance by country: Brazil: Admissible taxes

The following Brazilian taxes are admissible for credit in the UK under the air crews agreement:

The following Brazilian taxes are admissible for credit in the UK under the shipping and air transport agreement:

all taxes which are covered by the federal income tax law as well as any similar federal taxes or contributions on income or profits which are, or may become, chargeable in Brazil

These include the corporate income tax (IRPJ) and Social Contribution on Corporate Net Profits (CSLL).

The following Brazilian taxes are admissible for unilateral relief under the agreement:

the income tax (imposto de renda)
state income taxes (imposto de renda estadual)
the corporate income tax (imposto de renda das pessoas juridicas)
withholding tax imposed on income including tax charged on gross receipts, interest, royalties or dividends and the supplementary tax charged on dividends remitted abroad in excess of 12% registered capital
social contributions tax (contribuicao social)
additional tax on the income tax

The following payments to the following development funds are admissible under the agreement:

The following are inadmissible for unilateral relief under the agreement:

2% municipal tax on services (imposto sobre servicos de qualquer natureza)
8% withholding tax on the net income of corporate entities. (If the 8% withholding tax is offset against the 25% withholding tax payable on a dividend to a non-resident shareholder, credit is available for the net amount actually paid and the 8% set-off)
tax on financial transfers (imposto sobre operacoes financiaras)
distribution tax
programa de Integracao (PIS) (1989 onwards)
contributions to the Social Investment Fund (FINSOCIAL)
Contribuicao para o Finaciamento da seguridade social (COFINS)

The following payments are inadmissible for the development funds under the agreement:

Double Taxation Relief Manual