In December/2022, Provisional Measure No. 1,148/2022 was issued, which aims to amend Law 12,973/2014 regarding the taxation, by the Brazilian parent company, of the profits of controlled and associated companies abroad.
The change extends until the end of 2024 the possibility of using the presumed 9% credit on income applicable to the positive portion computed in real profit related to investment in legal entities abroad that carry out activities involving the manufacture of beverages, the manufacture of food products and the construction of buildings and infrastructure works, in addition to other industries in general.
The possibility of considering, on a consolidated basis, the value of the investment in a direct or indirect subsidiary abroad in determining the real profit and the CSLL calculation basis of the parent company in Brazil was also extended until 2024.
