Categoria: English

  • The Importance of Document Accuracy in International Transactions

    In international transactions, the divergence between what was actually agreed by the parties and what appears in formal documents represents one of the greatest legal risks for investors and companies. When contracts, property registries, customs declarations, or tax filings fail to reflect operational reality, paper usually prevails over informal understandings.

    Sometimes, the financial value stated in documents is incorrect. At other times, the entity named in the contract is the wrong party. In the worst-case scenarios, the parties involved end up disputing who the true owner of an asset is, or whether anyone actually owns anything at all.

    Incorrect Values and Parties

    It is common for documentary discrepancies to arise from attempts to reduce tax or customs costs. However, these choices can drastically limit the rights of the parties involved in a subsequent dispute.

    A practical example reported in the market involved the sale of a Russian aircraft. Although the real transaction price was US$ 6 million, the documentation recorded a value of US$ 3.65 million to reduce the tax burden in Russia. When a payment issue arose requiring judicial action, collecting the actual amount became legally unfeasible because the documentation did not support the claim.

    A similar situation occurred with a major maritime shipping company. A damaged cargo had an estimated actual value of US$ 2 million, but the shipping manifest declared only US$ 500,000 to lower the shipper’s customs costs. When the cargo was damaged, the owner sought compensation for the full actual value. However, the final settlement for damages reflected the manifest, remaining limited to the amount declared in the original document.

    Errors in identifying the parties also create severe deadlocks. In one international investment case, a Taiwanese company invested US$ 8 million in a U.S. company. However, the documents provided for the issuance of shares to a second Taiwanese company. When the relationship between the two Asian companies deteriorated, it became unclear whether the second company had received the shares or what its legal status was. It became nearly impossible to trace and reconstruct the US$ 8 million transaction because the documents named a different company from the one that actually paid.

    The Challenge of Ownership in Complex Structures

    Ownership issues become even more difficult to resolve when documentation fails to clearly align the legal owner, the beneficial owner, and the source of funds.

    In a case involving a Chinese company planning an initial public offering (IPO), the corporate structure utilized an operation known as a round-tripper. The company was wholly owned by a U.S. LLC that had not filed or paid taxes for over a decade. This LLC, in turn, belonged to a cousin of the Chinese founder, whose whereabouts in the United States were unknown. On paper, the founder did not own his own company. Prior to any public offering, the company needed to determine who owned the LLC and what liabilities it carried, which brought the transaction to a halt.

    Ownership disputes can reach billions of dollars. In 2017, litigation in the Cayman Islands involved claims by Chinese billionaire Xie Zhikun that he had invested approximately US$ 940 million (5.8 billion yuan) across structures to fund the London-based private equity firm XIO Group. The CEO of XIO denied that Xie was an investor. The claim relied on a share entrustment agreement (share entrustment agreement) through a Cayman Islands entity called Dorsey Ventures, in which another individual was the registered owner while Xie claimed to be the ultimate beneficial owner.

    The case generated years of court proceedings in the Cayman Islands Court, including appeals, without ever reaching trial. In August 2020, the parties reached a settlement, and the lawsuit was dismissed without any admission or finding of liability. The episode demonstrates that when the legal owner, the alleged beneficiary, the source of capital, and the individuals controlling the investment are not clearly aligned on paper, parties can spend years and fortunes litigating what the true agreement was.

    The Importance of Document Accuracy

    These cases share a central problem: the gap between what documents state and what parties actually did. Documents structured to obtain regulatory advantages, minimize taxes, or conceal ownership often become the upper ceiling of what can be recovered in a dispute.

    To mitigate these risks in foreign direct investment and cross-border transactions, it is essential to draft the agreement that was actually made. Formal documentation must accurately reflect transaction terms, financial amounts, and the true identity of all parties.

    This content is for informational purposes only and does not constitute legal advice. For guidance on specific matters, consult a qualified lawyer.

  • Nullity of Out-of-Court Auctions Due to Lack of Publication

    The validity of asset repossession procedures requires strict compliance with formal steps. News reported by the legal portal Consultor Jurídico (ConJur) highlights a fundamental understanding for the sector: the failure to publish a notice summons in a newspaper is sufficient cause to annul an out-of-court auction.

    The mechanism of out-of-court auctions in Brazil

    An out-of-court auction (leilão extrajudicial) is a procedure that allows the sale of an asset to settle a debt without the need for a lengthy judicial lawsuit. This mechanism is widely used in the Brazilian real estate market, providing greater agility in credit recovery for financial institutions and creditors.

    For foreign investors and investment funds operating in Brazil, extrajudicial auctions represent a channel for acquiring real estate assets. However, the speed of this system is counterbalanced by strict validity requirements. One of the central principles of this procedure is ensuring that the debtor has unequivocal notice that their property will be put up for auction. This formal communication is known as a summons or notification (intimação).

    Summons by public notice and publication requirements

    As a rule, debtor notification must be carried out personally. When the individual cannot be located, the formal alternative is summons by public notice (intimação por edital). A public notice is an official announcement designed to establish the legal presumption that the information reached the interested party when direct contact attempts have failed.

    According to the situation reported by ConJur, simply issuing the notice document is not enough; its actual publication in a newspaper is mandatory. The absence of this publication in a press outlet removes the necessary publicity from the act. Without fulfilling this formal step, the individual is deprived of the opportunity to settle the debt or challenge the proceeding. Consequently, the lack of publication invalidates the entire out-of-court auction.

    Practical impacts for real estate investors

    For the real estate market, non-compliance with formalities such as newspaper publication represents a significant operational and financial risk. The annulment of an out-of-court auction, especially after the asset has been purchased (arrematação), creates transaction instability, delays property transfers, and leads to potential disputes.

    This scenario underscores the need for thorough prior audits, known as due diligence, before acquiring assets at auction. It is essential to verify not only the physical and commercial condition of the property, but also the legal regularity of the entire foreclosure procedure. The review must confirm whether all communication steps, including newspaper notice publications, were strictly followed by the party conducting the auction.

    Compliance with summons requirements ensures the stability of the acquisition. For companies and investors, understanding the importance of these legal formalities is the first step toward structuring safe transactions and mitigating risks in the real estate market.

    This content is for informational purposes only and does not constitute legal advice. For guidance on specific matters, consult a qualified lawyer.

  • Split Payment in Installment Sales: Tax Debits and Credits

    Split Payment in Installment Sales: Tax Debits and Credits

    The advancement of financial technologies and the consolidation of online marketplaces have introduced new dynamics to the retail sector. Among the most widely adopted innovations is split payment (payment division). However, applying this model to installment sales raises a central tax question: when exactly do the tax debit and credit arise?

    The Dynamics of Split Payments

    Split payment is a tool that enables the automatic division of a purchase amount among different recipients at the exact moment of the transaction. In a typical e-commerce scenario, for instance, the amount paid by the consumer can be simultaneously allocated between the merchant, the sales platform (marketplace), and the payment institution (fintech).

    This automation delivers efficiency, mitigates default risks among participants, and simplifies financial management. However, from a tax perspective, the presence of multiple parties and the immediate division of financial flows require a careful analysis of the tax responsibilities assigned to each participant in the commercial chain.

    The Complexity of Installment Sales

    When an operation using split payment occurs in a single up-front payment, identifying the timing of the transaction and its respective taxation is usually straightforward. The scenario becomes considerably more complex in installment sales.

    In the Brazilian market, installment purchases are an entrenched commercial practice, vital for retail sales volume. When a sale is split into multiple monthly installments, and that same transaction utilizes automatic split payment technology across different companies, a technical debate arises regarding the exact moment the tax obligation is triggered.

    The Timing of Tax Debits and Credits

    The core discussion centers on defining the legal milestone that marks the emergence of the debit (the legal obligation to pay the tax to the State) and the tax credit (the company’s right to offset amounts previously collected along the supply chain). The key questions guiding this debate include:

    • Should tax recognition occur entirely at the moment the original sale is approved, regardless of the number of installments?
    • Or should debits and credits be assessed progressively, as each installment is effectively paid by the consumer and the amount is distributed to the respective recipients?

    Defining this milestone directly impacts the cash flow of the businesses involved. A potential mismatch between the timing of tax payment and the actual financial receipt of installment amounts can significantly affect the liquidity of merchants, suppliers, and technology platforms.

    Impact on Retail and Fintechs

    For retail companies and the fintechs providing payment infrastructure, understanding this dynamic is critical for financial and operational planning. Structuring commercial operations that involve automated disbursements requires clarity on how and when taxes apply to each share of the payment.

    Monitoring discussions surrounding the timing of tax debit and credit assessments enables companies to adapt their billing systems and avoid unexpected tax liabilities, maintaining fiscal compliance in an increasingly digitalized business environment.

    This content is for informational purposes only and does not constitute legal advice. For guidance on specific matters, consult a qualified lawyer.

  • Approval of Bill PLP 124/2022 and Tax Arbitration in Brazil

    The Brazilian National Congress recently approved Supplementary Bill (PLP) 124/2022, a measure that paves the way for consensual dispute resolution in Brazilian tax matters.

    The special arbitration proposal

    The central focus of the approved bill is to introduce new mechanisms to resolve disputes between taxpayers and the tax authorities, the government bodies responsible for tax inspection and collection. According to the text, dispute resolution will take place through special tax and customs arbitration.

    Impact on tax dispute resolution

    Arbitration is a dispute resolution method in which the parties agree to submit their case to independent experts, offering an alternative to traditional court litigation. By proposing this model for tax and customs matters, PLP 124/2022 seeks to foster a more consensual environment between the State and taxpayers.

    Congressional approval represents a shift in Brazil’s approach to tax litigation, introducing consensual mechanisms into a field traditionally marked by lengthy court proceedings.

    This content is for informational purposes only and does not constitute legal advice. For guidance on specific matters, consult a qualified lawyer.

  • STJ maintains conglomerate companies in anti-corruption lawsuit

    STJ maintains conglomerate companies in anti-corruption lawsuit

    Ruling of the 1st Panel of the STJ

    The Superior Court of Justice (STJ, Brazil’s highest appellate court for non-constitutional matters), through its 1st Panel, issued a relevant decision for corporate groups. The court ordered the maintenance of companies belonging to the same conglomerate in a lawsuit involving the Brazilian Anti-Corruption Law.

    The requirement for evidentiary review

    The core issue of the decision was the inability to dismiss the companies from the proceedings prematurely. According to the 1st Panel’s understanding, it is not possible to exclude the companies from the lawsuit without a prior and detailed analysis of the evidence.

    Impact on corporate governance

    For foreign investors and executives operating in Brazil, the case reinforces the importance of corporate governance and monitoring the operations of all entities that make up an economic group. The decision indicates that courts exercise caution before dismissing companies belonging to the same conglomerate in anti-corruption investigations, requiring the evidentiary phase to determine the situation of each member.

    This content is for informational purposes only and does not constitute legal advice. For guidance on specific matters, consult a qualified lawyer.

  • CARF rules against concurrent application of tax penalties

    CARF rules against concurrent application of tax penalties

    The Administrative Council of Tax Appeals (CARF — Brazil’s federal administrative tax court) has issued a significant decision regarding tax enforcement. With its full bench, the tribunal reviewed the simultaneous application of penalties to taxpayers.

    Shift in precedent and vote count

    The collegiate body decided against the concurrent imposition of isolated penalties (multa isolada) and ex officio penalties (multa de ofício). The outcome was decided by a 9-to-1 vote. This judgment marks a shift in understanding within the administrative tribunal.

    Impact on the tax landscape

    The decision strengthens the argument against the simultaneous assessment of these tax penalties. The fact that the ruling was handed down by the full bench lends substantial weight to this position, impacting the legal assessment of tax deficiency notices.

    This content is for informational purposes only and does not constitute legal advice. For guidance on specific matters, consult a qualified lawyer.

  • ANPD Examines First Major Case Involving Brazil’s ‘Digital ECA’

    The National Data Protection Authority (ANPD, Brazil’s data protection regulator) is facing its first major case involving the protection of children and adolescents online, within the framework referred to by authorities as the “Digital ECA” (Digital Child and Adolescent Statute).

    Scrutiny over digital platforms

    The Brazilian executive branch is currently focusing its attention on the Discord platform. The scrutiny began after police identified suspects accused of inducing a 13-year-old girl to her death during a livestream on the service.

    This episode marks a milestone in how authorities approach child safety across digital channels. ANPD’s intervention indicates that incidents occurring on communication and video streaming platforms are subject to close regulatory oversight regarding the protection of underage users.

    Impacts on digital governance

    The case highlights the intersection between digital platform operations and legal duties concerning child protection. For technology companies, executives, and foreign investors operating in the Brazilian market, this landscape underscores the necessity of monitoring policies within virtual environments.

    Regulatory attention to the issue suggests that compliance with child and adolescent protection standards will serve as a central factor in assessing the governance of digital services in the country.

    This content is for informational purposes only and does not constitute legal advice. For guidance on specific matters, consult a qualified lawyer.

  • Casas Bahia Files for Judicial Restructuring: R$ 17.3 Billion Debt

    Casas Bahia Files for Judicial Restructuring: R$ 17.3 Billion Debt

    Retailer Casas Bahia has filed for judicial restructuring due to debts totaling R$ 17.3 billion. The move comes two years after the company requested an out-of-court restructuring, marking a renewed effort to stabilize its operations.

    Transition Between Restructuring Models

    Out-of-court restructuring — a preliminary mechanism to renegotiate debts directly with creditors — was the first alternative sought by the company. However, faced with the need for a broader reorganization, the retailer has now opted for judicial restructuring. This model is a formal court-supervised process that allows the company to renegotiate its liabilities in a structured manner while maintaining its business operations.

    The Goal of the Turnaround

    The petition involving R$ 17.3 billion reflects the complexity of the company’s financial situation. Transitioning to court-supervised restructuring indicates a search for a protected legal framework to organize payments to creditors and ensure business continuity, preserving the company’s position in the retail market.

    This content is for informational purposes only and does not constitute legal advice. For guidance on specific matters, consult a qualified lawyer.

  • STF Rules Against Calculating IPTU Tax Rates Based on Property Area

    The STF (Brazil’s Supreme Federal Court) has issued a significant decision for the real estate sector and municipal taxation in Brazil. The Court established that municipalities cannot calculate the tax rate for the IPTU (Urban Property Tax) based on the area of the property.

    The Property Area Criterion

    The IPTU is a municipal tax levied annually on urban property owners. The STF decision focuses specifically on how the tax rate — the percentage applied to the tax assessment basis to determine the final tax amount — is set by local city administrations.

    According to the Court’s ruling, the physical size of the property is not a valid criterion for defining the IPTU tax rate. This limitation prevents municipal governments from using square footage as a justification to apply differing tax percentage brackets to taxpayers.

    Impacts of the Decision

    The STF ruling provides clearer boundaries regarding the limits of municipal taxation authority when levying property taxes. For investors, real estate companies, and owners of large land parcels, the decision establishes an important safeguard against tax assessments based exclusively on the physical extent of real estate developments.

    This content is for informational purposes only and does not constitute legal advice. For guidance on specific matters, consult a qualified lawyer.

  • Tax Reform: Attention to Intercompany Pricing

    Tax Reform: Attention to Intercompany Pricing

    The current Brazilian tax reform brings important points of attention for companies, particularly regarding intercompany pricing. The topic, recently highlighted by the legal news portal Consultor Jur%C3%ADdico, requires careful monitoring by foreign investors and corporate groups operating in Brazil.

    What is intercompany pricing?

    Intercompany prices refer to the amounts charged in commercial or financial transactions between entities belonging to the same economic group. For foreign investors and multinational corporations, establishing these prices is standard practice in the transfer of goods, services, or rights between headquarters and their branches or subsidiaries.

    Key Considerations under the Tax Reform

    With the changes proposed by the tax reform, the assessment and collection dynamics of taxes in Brazil will undergo a significant transition. In this scenario, the prices applied in related-party transactions become a central focus.

    Companies will need to observe how the new guidelines of the tax system impact their internal pricing policies. The main goal of this monitoring is to ensure operations remain compliant with Brazilian tax requirements, preventing operational inconsistencies during and after the transition period of the new rules.

    Corporate Monitoring

    For executives and financial managers, ongoing monitoring of legislative updates is recommended. Adapting intercompany pricing policies to the new tax reality will be a key step in maintaining tax compliance across both international and domestic corporate operations.

    This content is for informational purposes only and does not constitute legal advice. For guidance on specific matters, consult a qualified lawyer.