BRAZIL’S FEDERAL REVENUE SERVICE LAUNCHES PROGRAM TO REGULARIZE ASSETS IN BRAZIL AND ABROAD

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Membership is valid until December 15, 2024, and includes payment of income tax and fines.

The RERCT 2024 – Special Exchange and Tax Regularization Regime (Base Date: 12/31/2023) is a program created by Brazil’s Federal Revenue Service to regularize undeclared or unregistered financial assets in Brazil.

Its main objectives are to combat tax evasion, encourage the repatriation of resources from abroad, and expand the tax base. The program aims to grant amnesty for tax-related offenses tied to regularized assets while reducing taxes and penalties. In addition to regularizing financial assets, it provides taxpayers with other benefits, such as reducing legal risks.

Key Requirements
Participants must declare unregistered assets, pay income tax (15%), and a fine (100% of the tax), along with adhering to the regime within the deadline established by the regulations.

The Federal Revenue Service (RFB) issued Normative Instruction No. 2,221 on September 19, 2024, to regulate the General Special Regime for Exchange and Tax Asset Regularization (RERCT-General). The program allows individuals and legal entities to regularize legally sourced assets held in Brazil or abroad.

To join RERCT-General, taxpayers must voluntarily declare the assets, rights, and resources they held as of December 31, 2023.

Deadline and Payment Requirements
The deadline to join the regime is December 15, 2024. Taxpayers must submit the regularization declaration and pay 15% income tax on the value of the assets, along with a fine equivalent to 100% of the tax. This totals 30% of the asset value, which must be paid by the stipulated deadline, in accordance with Federal Revenue Service rules.

How to Submit the Declaration
The Currency and Tax Regularization Declaration (Dercat) will be available for completion and submission through the “Declarations and Statements” service on the Virtual Service Center platform.

Program Context and Benefits
The RERCT-General, established by Law No. 14,973 of September 16, 2024 (Articles 9 to 17), was created to facilitate the declaration and regularization of undeclared or improperly declared assets. Following the model of previous programs in 2016 and 2017, this regime now also includes assets held in Brazil.

The program provides taxpayers the opportunity to regularize their tax situation, avoid future complications, and pay 30% of the asset value as tax and fines.

Relevant Legislation

  • Law No. 14,973, of September 16, 2024 (Articles 9 to 17)
  • Law No. 13,254, of January 13, 2016 (Original RERCT)

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