Ultimate Beneficial Owner

4 . December . 2018 |

The Brazilian Federal Revenue (“BFR”) has enacted the Normative Ruling No. 1,634/2016, ruled by the Executive Declaratory Act Cocad No. 9/2017 (“Regulation”), where the entities enrolled with the Brazilian Taxpayers’ Registry (so-called “CNPJ”) are required to provide additional information/documents regarding their “ultimate beneficial owners”.

Based on the Regulation, the ultimate beneficial owner of a certain entity is qualified as either:
• The individual who ultimately, directly or indirectly, owns, has significant influence or controls such entity; or
• The individual on behalf of whom a transaction/business is carried out.

Note that specific procedures and exceptions shall apply depending on the structure of the relevant legal entity and how its ultimate beneficial owner (if any) is qualified.

In this context, we would like to remind you that the deadline to submit the required documents/information to the Brazilian Federal Revenue is December 31, 2018.

For further information, contact:

Rodrigo Roso

Marcelo Frioli Droghetti

Nicolle Zennaro

Isabella Di Gregorio

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