From the Embassy of the Federative Republic of Brazil.
On December 9th 2015, the Law 13.202 entered into force, expanding the tax relief coverage granted by the Brazilian Government through double taxation agreements, including the one with the Netherlands.
In accordance with Article XI of the Law 13.202/15, “international agreements and conventions concluded by the Government of the Federative Republic of Brazil to avoid double taxation of income include the CSLL”.
Therefore, the Brazilian tax authorities have recognized that, in addition to the Corporate Income Tax (IRPJ), already regulated by the double taxation agreement, the “Social Contribution on the Net Profit” (CSLL) is also covered.
CSLL is charged separately form the IRPJ. The tax basis of the CSLL is the net profit specifically calculated for its payment purposes. The Social Contribution is levied on the legal persons and entities subject to the law of income tax, and it is intended to finance the social security system.
Further questions should be forwarded to the Brazilian Tax Authority (http://idg.receita.fazenda.
Brazilian Embassy in The Hague: http://haia.itamaraty.gov.br/
