• Service: Tax, Transfer Pricing, International Tax
  • Type: KPMG information
  • Date: 7/3/2012

Tax News: Normative Instruction 1,277 

New tax obligation for specific transactions entered into between Brazilian residents and non-residents


Normative Instruction 1,277, published on June 29th, 2012 (“IN 1,277/2012”), established a new tax obligation under which specific transactions entered into between Brazilian residents and non-residents must be formally informed to the Federal Revenue Services through an electronic system (“e-CAC”).

The transactions to be informed, by Brazilian individuals or entities, comprise the ones related to (i) the provision (export) or purchase (import) of services, (ii) transfer or acquisition of intangible assets and (iii) any other transaction that may change the equity position of the parties involved, which are described in Decree 7,708/2012 (Brazilian Nomenclature of Services, Intangibles and Others – “NBS”) (v.g. import and export of services and transactions performed abroad through branches and controlled entities). Note that the import/export of goods and eventual services and intangibles attached to such goods, which shall be registered within the Integrated Foreign Trade System (“Siscomex”), shall not be informed under such new tax obligation.

According to IN 1,277/2012, transactions involving services and/or intangible assets shall be informed within a 30-day period, except for those performed before December 2013, which shall be informed within a 90-day period. Transactions performed abroad through branches and controlled entities shall be informed as of 2014, until the last working day of June, in relation to operations performed in the previous calendar year.

The requirements established by this new Normative Instruction are in force as from June 29th, 2012.

For more information, please contact a tax professional with KPMG in Brazil:

International Corporate Tax Group

São Paulo

Marienne Coutinho, +55 11 2183-3182,
Ericson Amaral, +55 11 2183-3375,
Murilo Mello, +55 11 2183-3261,
Fabiana Pereira, +55 11 2183-6571,
Fernando R. Martins, +55 11 2183-3284,
Valter Shimidu, +55 11 2183-3269,

Rio de Janeiro

Roberto Haddad, +55 21 3515-9469,
Julio C. de Cepeda, +55 21 3515-9133,

Global Transfer Pricing Services Group

São Paulo

Eliete Ribeiro, +55 11 2183-3288,
Henrique Conti, +55 11 2183-3278,
Evandro Tiba, +55 11 2183-1824,
Ricardo Roa, +55 11 2183-6596,

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