TaxUp Consultoria Tributária
TaxUp Consultoria Tributária is a Brazilian tax advisory firm.
When does Brazilian Pillar 2 apply to my group?
“Pillar 2 OECD applies to multinational groups with consolidated annual global revenue of €750 million or more in at least 2 of the last 4 fiscal years. Below threshold: no Pillar 2 obligation.”
View in the company profileCan we use JCP instead of dividends to avoid the 10% WHT?
“JCP (Interest on Equity) is taxed at 15% WHT at recipient but is deductible at Brazilian company level (34% IRPJ/CSLL saving). Net effective benefit: approximately 19% compared to dividend (which has 10% WHT post-2026 but no deduction at company level).”
View in the company profileHow does Brazilian Pillar 2 interact with home jurisdiction Pillar 2?
“Brazilian QDMTT is "Qualified" — meaning it is designed to be collected by Brazil first, taking priority over the parent jurisdiction's top-up tax. If Brazilian ETR is below 15%, Brazil collects the top-up; the parent jurisdiction does not also collect on the same Brazilian profits.”
View in the company profileWhat is the effective tax cost of remitting BRL 10M in royalties to parent abroad?
“Cumulative impact: CIDE-royalties 10% + WHT 15% + partial non-deductibility = effective tax cost of approximately 35-40% on remitted value. For BRL 10M royalty, total Brazilian tax burden is approximately BRL 3.5-4M.”
View in the company profileDoes Brazil have a tax treaty with the US?
“No — there is no double taxation treaty in force between Brazil and the United States. Treaty has been under negotiation for decades but never finalized.”
View in the company profile