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December 28, 2018

Normative Instruction RFB No. 1,863/2018 postpones the deadline for informing the Ultimate Beneficial Owner (UBO)

Tax

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:

  • Specification on the entities subject to an exception on the provision of information of the individual that ultimately has direct or indirect control or significant influence;
     
  • Exclusion of investors in Private Equity Investment Funds (FIP) from the list of exceptions on the filing of UBO information;
     
  • Creation of a new form (Ficha de Beneficiários Finais) to be filled by the companies’ legally constituted representatives;
     
  • Postponement of the deadline to file the UBO information for an extra 180 (one hundred and eighty) days as of today.

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.

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