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.”
在公司資料中查看Can 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).”
在公司資料中查看How 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.”
在公司資料中查看What 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.”
在公司資料中查看Does 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.”
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