ITSNewsalert: Disclosure of final beneficiaries in Brazilian corporate taxpayer register

On December 29, 2016, the Brazilian tax authorities issued Normative Instruction (NI) 1,684/2016 which postpones the starting date to disclose information related to final beneficiaries in the Brazilian corporate taxpayer register (“CNPJ”).


In May 2016 the Brazilian tax authorities issued NI 1,634 establishing the obligation to disclose information related to final beneficiaries of Brazilian companies in the CNPJ.

According to NI 1,634, the term “final beneficiaries” refers to (i) an individual who ultimately, either directly or indirectly, holds, controls or significantly influences an entity; or (ii) an individual on whose behalf a transaction is undertaken. A shareholder is deemed to have significant influence if (i) owns more than direct or indirect 25% of the entity’s capital stock or (ii) has the ability to influence the decision-making and elect or appoint members of the entity’s management.

Please note that, among others, legal entities set up as listed companies in Brazil, or in jurisdictions which impose the public disclosure of information of relevant shareholders, as well as non-profit entities, were not required to comply with this obligation unless the entities were located in tax havens or privileged tax regimes under the Brazilian tax legislation.

The takeaway

Although the disclosure of the final beneficiaries was initially set to start on January 1, 2017, NI 1,684/2016 has postponed the general starting date to July 1, 2017. As an exception, companies registered in Brazil before July 1, 2017 will have time until December 31, 2018 to comply with the disclosure obligation (however, please note that if a Brazilian company updates its CNPJ before December 31, 2018 for any other reason, the disclosure obligation will arise at the date of such change).

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If you would like to discuss the implications for your organisation, please contact your usual PwC adviser or:

Daniel Gremaud
PwC | Senior Partner, Tax and Legal Services
Office: +41 58 792 81 23
Mobile: +41 79 213 5459
PricewaterhouseCoopers GmbH
Avenue C.-F. Ramuz 45 | Case postale | 1001 Lausanne



Grasiele Teixeira Neves
PwC | International Tax Services
Office: +41 58 792 9825
Mobile: +41 79 350 5138
PricewaterhouseCoopers AG
Avenue Giuseppe-Motta 50 | Case postale | 1211 Genève 2

Invitation Webcast: US Tax Reform and Impact on Companies Investing in the US

Wednesday, January 18, 1:00 pm.- 2:00 pm ET

Online registration

Whatever your resolutions, the start of a new year offers opportunities for new beginnings and improvements. As you look at 2017 and what’s ahead for your business, PwC’s Doing business in the United States can help guide you through the US tax system as you invest or expand your investments in the United States.

Wondering what’s the outlook for the US tax system this year? Join PwC for a closer look at tax reform and other tax policy issues specific to global companies investing in the United States.

Wednesday, January 18, 1:00 pm.- 2:00 pm ET


  • How is the US tax system unique?
  • What is the process of transforming tax reform into US law?
  • What are the option for tax reform and how do they compare and contrast (Camp plan, Trump proposal, Republican Blueprint)
  • What are the consequences for US inbound companies, from interest
    educibility, treatment of intangibles, state taxes, and border adjustability?


  • Chris Kong, US Inbound Tax Leader
  • Peter Merrill, US National Economics and Statistics Principal
  • Pam Olson, US Deputy Tax Leader & Washington National Tax Services Leader
  • Oren Penn, US Inbound Tax and International Tax Services, Principal

For further details please refer to our registration page.

US Treasury Releases White Paper on European Commission’s State Aid Investigations into Transfer Pricing Rulings

On 24 August 2016 the US Treasury released a White Paper on the European Commission (EC)’s recent State aid investigations of transfer pricing rulings. The White Paper acknowledges the shared view of the US Treasury and the EC on tax avoidance by multinational companies, but also outlines the US Treasury’s concerns with the EC’s approach. According to the US Treasury, the EC’s approach is new and departs from prior EU case-law and EC decisions. The US Treasury thus suggests a return to the system of international tax cooperation that has long fostered cross-border investment between the US and the EU Member States. It remains to be seen how the EC and the European Courts will deal with the disputes arising in this area of interaction between State aid, tax measures and transfer pricing.

Please see below the full text of the White Paper as well as the summary prepared by our EU Direct Tax Group (EUDTG).


Download White Paper


Download summary

Liechtenstein Proposes First Beneficial Ownership Registry

Interview on Bloomberg BNA

flaga-liechtensteinu-70-x-110-cmLiechtenstein companies for the first time would have to disclose the identities of their ultimate owners under a proposal to come in line with European anti-money laundering recommendations.

But in the Liechtenstein tradition, practitioners say, that information wouldn’t be publicly accessible.

The 193-page consultation, released for comment July 12, proposes to require all financial intermediaries who enter a business relationship to identify the contractual parties, the beneficiaries and the origin of the assets and submit this information to the principality’s Financial Intelligence Unit. It also proposes creation of the principality’s first beneficial ownership registry.

Changes would come in amendments to jurisdiction’s 2008 Due Diligence Act.

High Risk

The proposed changes aim to implement into Liechtenstein law the Fourth EU
Anti-Money Laundering Directive (EU 2015/849), which requires EU member countries to track the beneficial ownership of various financial vehicles to prevent funds from being used for terrorism and various financial crimes.

Liechtenstein isn’t a European Union member country, but as a member of the European Economic Area it is required to transpose this directive into its national legislation.

The changes are also aimed at implementing recommendations from the International Monetary Fund, which assessed the extent to which Liechtenstein met the global standards against money laundering and terrorist financing set out by the Financial Action Task Force intergovernmental body in 2014.

The 2014 IMF report said Liechtenstein’s financial sector heavily focuses on private banking, wealth management and non-resident business, which it said put the country at “high risk” for money laundering. The IMF recommended a review of all financial secrecy provisions and advised Liechtenstein authorities to require enhanced due diligence from trust and company services providers.

“Liechtenstein Tradition.”

Martin_Meyer_09723Martin Meyer, tax director at PwC in Liechtenstein, told Bloomberg BNA July 15 that both the amendments to the Due Diligence Act and the draft law establishing a beneficial ownership registry fall squarely within the “Liechtenstein tradition.”

Noting that Liechtenstein’s role as a financial hub and its extensive private wealth sector, he said successive administrations have always put the protection of clients’ information first.

He said the proposal doesn’t provide public access to the beneficial ownership registry. “It only grants access if a real interest in knowing or receiving such information exist, for instance in case suspicion of money laundering or financing of terrorism exists,” he said.

“Liechtenstein wants to protect the information of the individual to the extent possible, but also comply with all global standards,” Meyer said. “As a member of the European Economic Area, they have to implement EU law to comply with EU standards.”

If you have any questions, please contact me.