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(d) it is possible to establish another period for
the payment of the tax, as from the date of remittance
of the interest to the foreign lenders, because of the
complex calculation of the interest and consequently of
the tax itself;
(e) it is possible, in space 31 of the DARF, to
indicate “Brazilian Financing Plan” as a reference,
given the absence of a Certificate of Registration for
these transactions;
(f) in the event that the income tax is paid late:
(f)(1) whether the Bank will nevertheless be
entitled to the above-mentioned pecuniary benefit;
(f)(2) whether it would be possible to waive
the monetary correction, delinquent interest and
penalty.
(3) Interest received by individuals or legal entities,
resident or domiciled abroad, from individuals or
entities resident or domiciled in Brazil, or received
from a permanent establishment located in Brazil, owned
by individuals or legal entities resident or domiciled
abroad, is subject to withholding tax at the rate of
25%, as provided for * * * [by law]. The contributor *
* * of this tax is an individual or legal entity,
resident or domiciled abroad, which has the legal
availability of the interest. Said tax must be
withheld at the time of payment or credit by the
interest paying source bearing in mind that the
contributor * * * individual or legal entity, resident
or domiciled abroad--does not file an income tax return
in Brazil. Said tax must be withheld even if the
paying source is a legal entity of public law with tax
immunity, because this is not a tax on the entity of
public law that has immunity but rather on parties
resident or domiciled abroad.
(4) It is obvious that, if the party resident or
domiciled abroad, the interest creditor, is immune or
exempt from this tax, on account of international
treaty or domestic legislation, the tax should not be
withheld. In the case of the interest paid by the
Central Bank * * *, there is an atypical situation. *
* * [The Central Bank] is a federal government agency
(autarquia) responsible, among other duties, for
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