Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 15

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          thereon; correspondingly, the Brazilian borrower received no                
          subsidy.                                                                    
               If the 432 program loan was a gross loan, the Central Bank             
          would pay the withholding tax due on the interest payable to the            
          foreign lender during the period the funds were deposited in the            
          Central Bank.  If the 432 program loan was a net loan, the Central          
          Bank would pay no withholding tax with respect to the interest              
          payable to the foreign lender.                                              
          K.  Brazilian Tax Law in General                                            
               The Brazilian tax system is divided into three types of                
          authority: The Federal Constitution of Brazil (Federal                      
          Constitution), the National Tax Code, and ordinary Federal, State,          
          and municipal legislation.5                                                 
               The Federal Constitution divides the authority to tax among            
          the Federal Government, the States, and the municipalities of               
          Brazil.  Pursuant to Article 21 of the Federal Constitution, the            
          Federal Government has authority to impose all types of taxes,              
          including a tax on income, except as otherwise granted by the               
          Federal Constitution to the States or municipalities.                       




          5         The National Tax Code is a complementary law and has an           
          authoritative status below that of the Federal Constitution but             
          above that of ordinary laws.  Where the National Tax Code                   
          conflicts with an ordinary law, the National Tax Code will                  
          prevail.                                                                    





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