The State of Rio de Janeiro enacted the Resolution n° 265 on June 19, 2018, in order to allow taxpayers to regularize their tax debts before starting an official tax audit and to reduce the amount of credits in dispute before the administrative court.

The proceeding is called a “friendly warning” and encompasses tax debts not yet declared in ancillary obligations and also ancillary obligations not yet presented to tax authority by the taxpayers. Tax authority identifies possible outstanding tax debts and ancillary obligations not yet fulfilled by crossing electronic data available in its systems.
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The Brazilian Government has enacted Decree No. 9,422/2018, which introduced into Brazilian law the Agreement on Social Security between the United States and the Federative Republic of Brazil, originally signed on June 30, 2015.

 The Agreement was enacted in late June 2018; its enforceability shall commence on October 1, 2018 and shall be applicable to (i) individuals currently or previously covered under US or Brazilian laws, and/or (ii) individuals who, under the laws of either contracting state, may derive rights by virtue of their relationship to an individual subject to the laws of the US or Brazil.
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The Governments of Brazil and Switzerland have signed the Convention for Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (DTT). In line with Brazil’s commitments under the G20, the DTT, signed on May 3, 2018, incorporates certain minimum standards of the Organization for Economic Cooperation and Development (OECD) Project on Tax Erosion and Transfer of Profits (BEPS Project). It also includes an anti-abuse clause as well as an administrative assistance clause in accordance with the current international standard for exchange of information.
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