Скачать или смотреть Cross-border Tax Talks Podcast | BRAZIL TAX UPDATE: FULL INCLUSION - FULL IMMERSION | Romero Tavares

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Dr. Romero Tavares, PwC Brazil’s International Tax Leader and a professor of international tax law in São Paulo. Doug and Romero discuss the increasing intersection between Brazil’s international tax policy and global trade dynamics, including the effects of recent US executive orders. They cover Brazil’s high-tax corporate environment, its historically aggressive CFC-like full inclusion regime, and the country’s rapid adoption of a qualified domestic minimum top-up tax (QDMTT). The conversation explores the political and policy rationale behind these moves, the anticipated redesign of Brazil’s CFC regime, and the operational challenges multinationals face with the new OECD-aligned transfer pricing rules. Romero also breaks down Brazil’s massive indirect tax reform and the country’s potential shift to more internationally-aligned tax norms, while questioning the long-term viability of the undertaxed profits rule (UTPR) and Pillar Two’s durability under changing geopolitical winds.

Timestamps and Descriptions

00:00 – Introduction to Romero Tavares and current political, tax, and trade climate in Brazil

04:15 – International confluence of tax and trade policy; looking at the big picture

05:40 – Brazil’s complex corporate tax regime and high tax environment

06:43 – Brazil’s reforming indirect tax system and the future VAT model

09:15 – Overview of Brazil’s full inclusion rules and their interaction with Pillar Two

13:30 – Implementation of OECD-aligned transfer pricing rules in Brazil

17:20 – Practical challenges of applying the new TP rules within Brazil’s economic model

18:30 – Introduction of Brazil’s QDMTT: policy, process, and political trade-offs

24:20 – Why Pillar Two could apply in Brazil despite its high headline tax rates

29:15 – The roadmap for reforming Brazil’s full inclusion/CFC regime

31:20 – How Brazil approached its QDMTT legislation and choice of accounting standards

33:00 – Brazil’s indirect tax reform: scope, timeline, and implementation challenges

40:50 – Potential changes to Brazil’s corporate tax, including dividend withholding

42:15 – Romero’s academic view on the future of Pillar Two and global tax coordination

47:20 – Legal and political headwinds facing the UTPR and multilateralism