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domiciled abroad or (2) grant pecuniary benefits to Brazilian
borrowers receiving loans in foreign currency.
Pursuant to that authority, borrowers taking out foreign
loans duly registered with the Central Bank were granted a
pecuniary benefit equal to 85 percent of the tax paid on the
interest, commissions, and expenses due on those loans.
Circular 266, issued by the Central Bank, set forth the
regulations governing the procedure for payment of the pecuniary
benefit:
(1) A DARF was to be used for the payment of the income tax
on interest paid on foreign currency loans;
(2) on the date of payment of the tax, the collecting
banking receiving the tax payment would, by means of a credit to
the borrower’s account, pay to the borrower the equivalent of 85
percent of the income tax;
(3) in the case of a Resolution 63 repass loan, on the date
of payment the borrowing bank would be obligated to transfer the
total value of the pecuniary benefit to the repass borrowers; and
(4) the collecting bank would debit the amount of the
pecuniary benefit to an account of the collecting bank entitled
“Pecuniary Benefit -- D.L. 1,411” (the pecuniary benefit
account), and on the same day as the payment of the tax to Banco
do Brazil the collecting bank would charge the pecuniary benefit
account against Banco do Brazil.
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Last modified: May 25, 2011