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On 13 September 2016 the Brazilian tax haven list (black list) and privileged tax regime list (grey list) were amended. In Normative Instruction 1,658/2016 the term 'substantial economic activity' was clarified. This clarification is of great importance for the role of Dutch holding companies. Further changes are the inclusion of the Austrian holding regime on the grey list and the inclusion of Ireland on the black list. The amendment shall have retroactive effect as of 1 August 2016.

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