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Instruction No. 1,681/2016


Memorandum - Tax | Brazilian Revenue Service enacts Normative Instruction No. 1,681/2016 governing the Country-by-Country Report under the BEPTS Project

Normative Instruction No. 1,681/2016 (“NI”), which was issued by the Brazilian Revenue Service (“RFB”), was published in the December 29, 2016 Official Gazette, introducing rules related to mandatory annual filing, by certain Brazilian multinational companies, of the Country-by-Country Report – (“CbC Report”). Filing of the CbC Report is an obligation agreed by Brazil under the Base Erosion and Profit Shifting (BEPS) Project, which is coordinated by the Organization for Economic Cooperation and Development – OECD.

As outlined in our November 10, 2016 Memorandum to Clients, the original draft of the NI was submitted to public consultation (Public Consultation No. 11/2016), by which certain entities and associations were given the opportunity to submit comments and suggestions.

Despite some relevant suggestions to the NI’s original version, its final version did not include many of the suggestions.

Below it is a chart highlighting some​ of the language in the NI’s original version and its final version.​

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