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Brazil Clarifies Calculation and Deduction of Interest on Net Equity — Orbitax Tax News & Alerts

Brazil has published Private Ruling No. 7018 of 21 March 2019 in the Official Gazette, which clarifies the calculation of shareholder interest on net equity (juros sobre o capital próprio - JCP). This includes that the calculation will take into account, exclusively, the following equity accounts: share capital, capital reserves, profit reservices, treasury shares, and accumulated losses. The Private Ruling also provides that the deductible portion of JCP for tax purposes is limited to the pro rata variation of the Long-Term Interest Rate (TJLP) corresponding to the time elapsed from the beginning of the calculation period up to the date of payment or interest credit to the shareholder.