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Brazilian tax authorities issue regulation on disclosure of ultimate beneficial owners

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January 2019


The Brazilian tax authorities on December 28, 2018, published Normative Instruction (NI) 1,863.  The NI provides guidance about disclosing the foreign beneficiaries of certain Brazilian and foreign corporations registered before the Brazilian corporate taxpayer identification registry (‘Cadastro Nacional das Pessoas Juridicas’ in Portuguese, or CNPJ).

This NI revokes prior regulations on the matter, provides detailed rules on the disclosure of ultimate foreign beneficial owners, and extends the deadline to report such information to the Brazilian tax authorities.

The takeaway

Multinational enterprises currently investing in Brazil should review their existing structures to determine whether they must comply with the new regulations requiring ultimate beneficiary disclosure by June 2019.

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Jose Leiman

Partner, PwC US

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