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(12) As the term for payment of the tax is suspended,
as far as the taxable events occurring while the
inquiry is pending are concerned, as a consequence, the
pecuniary benefit will be applicable in relation to the
tax paid by the thirtieth day from the date of
knowledge of the decision.
(13) As far as the extension of the tax payment period
is concerned, this matter falls under the authority of
the Minister of Finance * * *.
For higher consideration.
Brasilia, /Eivany Antonio da Silva/ Assistant Secretary
of * * * [the BRS]
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 BRS]
The ruling issued to the Central Bank was a private ruling
that was given limited circulation.7
Beginning in 1984, the Central Bank issued DARFs to the
agent banks of the foreign lenders to whom it transmitted loan
payments, reflecting its withholding tax payments on
restructuring debt interest remittances during the re-lending
periods of the loans. From 1984 through 1988 the Central Bank
issued a total of 324 DARFs to these agent banks. The Central
Bank did not issue a separate DARF to each foreign lender
specifying the withholding tax that had been paid by the Central
Bank on each foreign lender’s behalf on the interest remittance.
Rather, each DARF covered the collective withholding tax the
7The ruling was not made available to the public and was not
published in the Brazilian Government’s Official Gazette.
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