Newsletters 08/12/2010
Many governments face historic high levels of deficit and debt. To ensure sound public finances, they will need an appropriate balance between expenditure cuts and revenue increases. How additional revenues are raised is also important. OECD’s “Tax Policy Reform and Fiscal Consolidation” offers advice on how tax regimes can best support sustainable economic growth.These issues are further explored in two new Tax Policy Studies:
Tax Policy Study No. 19 details the rationale for tax breaks, asks whether they are still justified, and cites case studies such as VAT reduced rates and tax reliefs for house buyers. It notes that ”tax expenditures” are often entrenched in tax regimes and urges countries to evaluate whether they are worthwhile.
Tax Policy Study No. 20 recommends ways to make taxes less distortive and more growth-friendly. It also looks at the “political economy” of tax reform – why governments are able to design, legislate and implement growth-oriented tax reforms in some circumstances and not others and how to overcome obstacles.
O Secretário de Estado dos Assuntos Fiscais, Sérgio Vasques, emitiu ontem um despacho esclarecendo vários pontos sobre a aplicação do Regime Excepcional de Regularização Tributária (RERT II) e prorrogando o prazo para a entrega da respectiva declaração até 31 de Dezembro de 2010.
By Cristina Berry and Marcelo Natale - Deloitte Brazil
The Brazilian tax authorities announced on 2 December 2010 that Spanish ETVEs (i.e. holding companies) will be temporarily suspended from the effects of inclusion on the list of privileged tax regimes. The suspension, which comes after a formal review request was filed by the Spanish government, was published in the Official Gazette as Executive Declaratory Act (ADE) No. 22 and is effective immediately.
Guidance dated 7 June 2010 introduced procedures under which countries that are deemed to be tax havens (black list) or have privileged tax regimes (gray list) may request that their inclusion on the list be reviewed by the Brazilian government. Before ADE No. 22, only the Netherlands (gray listed) and Switzerland (black listed) had been formally granted temporary suspensions of the effects of being listed.
As was expected with the release of the June guidance, some political pressure has been exerted by foreign governments whose tax regimes are included on the lists, particularly those that have concluded a tax treaty and have substantial economic relationships with Brazil.
With effect from 2 December 2010, the suspension neutralizes the tax effects applicable to transactions involving Spanish ETVEs. The tax effects incurred during the period in which the rule was applied, however, are not affected by ADE 22. Further, it should be noted that there is no indication how long the suspension status will remain in effect.