Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 43

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               DECISION:  I agree fully with the conclusions of the                   
               attached opinion of the  *  *  *  [Brazilian IRS].  In                 
               view of item 13 of said opinion, I direct the Central                  
               Bank of Brazil to implement the payment of income tax on               
               or before the last business day of the month following                 
               the month in which the withholding is made.                            
               Brasilia, March 14, 1984                                               
               /Ernane Galveas/                                                       
               ERNANE GALVEAS                                                         
               Minister of Finance                                                    
               The Brazilian IRS ruling, which he enclosed to the Central             
          Bank, stated:                                                               
               Federal Government Service                                             
               Ministry of Finance                                                    
               *  *  *  [Brazilian IRS]                                               

                                       OPINION                                        
                         Income tax withheld on interest due                          
               to parties resident or domiciled                                       
               abroad                                                                 
               *  *  *  [FIRCE] of the Central Bank of Brazil requests                
               an opinion about the tax treatment of Agreements called                
               *  *  *  [CGA and DFA] under which such government agency              
               [autarquia] is liable for the payments and remittances                 
               pertaining to them, in the period of availability of such              
               funds for relending.                                                   
               (2) By virtue of the special characteristics of these                  
               transactions, the question arises as to whether there is               
               an incidence of income tax, in view of the government                  
               agency's [autarquia's] assumption of the burden, and if                
               so whether,                                                            
               (a) the DARF's may be issued in the name of the agent                  
               bank centralizing each project, considering that the                   
               large number of lenders makes it impractical to complete               
               one DARF for each of them;                                             
               (b) the tax rates established in the treaties signed by                
               Brazil to avoid double taxation may be applied;                        
               (c) the pecuniary benefit  *  *  *  applies;                           




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