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the large number of lender bankers makes it
impractical to issue one DARF in the name of
each of them;
(b) the payments are to be made individually
per agent/taxable event/tax rate in view of
the different tax rates available under
double-taxation treaties.
6. In view of the foregoing, we hereby ask also for
your opinion regarding the following aspects:
(a) if the Central Bank, in this case, is
entitled to the pecuniary benefit * * * ;
(b) the possibility of establishing a period
of 15 (fifteen) days for the payment of the
tax, such period to start as of the date of
remittance of the interest to the foreign
creditors, on account of the complex
calculation of the interest and consequently
of the tax itself;
(c) the possibility of indicating "Brazilian
Financing Plan" as the reference in space 31
of the DARF as there is no Certificate of
Registration for these transactions;
(d) in the event that the withholding tax is
paid late:
(i) whether the Central Bank would
nevertheless be entitled to such
pecuniary benefit;
(ii) whether it would be possible to
waive the ancillary charges (default
interest and monetary correction),
particularly as regards the penalty.
(e) whether the position to be adopted by
your Office can be extended to agreements of
identical characteristics that may be executed
in the future in a possible development of the
present negotiation phase.
(7) Finally, we point out that the matter is of special
importance for the completion of the mentioned
Agreements.
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