Earlier today (December 28, 2018) the Brazilian Federal Tax Authorities issued Normative Instruction RFB No. 1,863/2018, revoking the Normative Instruction No. 1,634/2016 and altering specific provisions regarding the National Registry of Legal Entities (CNPJ).
Among the changes, we highlight the provisions related to the filing of information on Ultimate Beneficial Owners (UBO), as follows:
Even though the postponement was announced on the last business day of the year, it is worth noting that the Brazilian Federal Tax Authorities were reasonable to acknowledge the need for a larger timeframe in order to obtain and organize the requested information.
We remain available to assist in the fulfillment of these obligations.