- 47 - For higher consideration. Brasilia, /Eivany Antonio da Silva/ Assistant Secretary of * * * [the Brazilian IRS] I agree with the above Opinion, which I approve. For the consideration of the Minister of Finance. Brasilia, /Luiz Romero Patury Accioly/ Acting Secretary of * * * [the Brazilian IRS] R. Foreign Lenders' Efforts During the Phase III Negotiations To Have the Central Bank Issue Them DARF's in Other Situations Not Covered in the March 1984 Brazilian IRS Ruling During the phase III negotiations, a number of foreign lenders sought to have the Central Bank issue them DARF's with respect to all of its net loan interest remittances to them, and not just on its restructuring debt interest remittances during the relending periods of the DFA's and the CGA's. The Brazilians rejected these efforts to have the Central Bank issue DARF's to the foreign lenders in additional situations outside the scope of the borrowers-to-be theory employed in the March 1984 Brazilian IRS ruling to the Central Bank. However, the Brazilians did indicate some willingness to negotiate a longer relending period with respect to the proposed phase III DFA. On January 5, 1985, the Brazilians submitted their written comments to a proposed draft of certain phase III basic business terms that had been prepared by the BAC. Their comments with respect to the Central Bank's provision of DARF's were as follows: WITHHOLDING TAX RECEIPTS In the first place, Pricing and Withholding Tax Receipts are intimately linked and shall be dealt with altogether.Page: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Next
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