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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Brazil: Underlying Tax

(1) Documents needed to support the underlying tax claim

The following documents will be required by the Underlying Tax Group

  • Page 1 Calculation of corporate income tax (Calculo do Imposto) and social contributions tax (Demonstrativo do Contribuicao Social)
  • Page 3 Profit and loss account (Demonstracao do Lucro Liquido)
  • Page 4 Option for application of fiscal incentives (Opcoes para aplicacao em Incentivos Fiscales)
  • Anexo A Liabilities and calculation of retained earnings (Passivo e Demonstracao page 2 dos Lucros ou Pre juizos Acumuladoes If you claim state income tax, attach copies of the relevant assessments (Air 1)

(2) Legal reserve

Relevant profits of corporations (SAs) but not limitadas (LTDAs) are reduced by transfers to a legal reserve until that reserve reaches 20% of capital or when added to capital reseres reaches 30% of capital, whichever is first.

(3) Admissability of interest payments on equity capital

Payments should be regarded as ‘dividends’ for the purposes of the unilateral relief provisions at section 790(6) ICTA1988.