Brazil Clarifies Taxation of Capital Contributions through the Assignment of Rights by Foreign Shareholders

Brazil recently published Interpretative Act 7/2016 in the Official Gazette of 24 August 2016. The Interpretative Act clarifies that a capital contribution through the assignment of rights by foreign shareholders is subject to withholding tax of 15% on the value of the rights. It also clarifies that the Contribution for Intervention in the Economic Domain (CIDE) will apply at the rate of 10% where the assignment of rights involves the acquisition of technical knowledge or technology transfer.…