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published on October 17, 2018 / reading time approx. 1 minute
An important change will happen in the system of National Registry of Legal Entities (CNPJ) from January 2019 that may affect your subsidiary directly if the necessary measures will not be taken in due time.
By means of Normative Instruction RFB 1.634 / 2016, all legal entities enrolled in the National Registry of Legal Entities (CNPJ) are required to inform the Brazilian Federal Revenue Office who are their final beneficiaries. The final beneficiary is understood as the natural person who, in the last instance, directly or indirectly, possesses, controls or significantly influences the entity.
The main purpose of this rule is to fulfil the necessity of knowledge by the Federal Revenue regarding the entire chain of companies involved in that specific CNPJ. Thus, with access to this information, the Brazilian Federal Revenue seeks to see the final individual of said corporate structure, whether in Brazil or abroad, the so-called “ultimate beneficiary of society”.
All entities registered with the CNPJ that have legal entities as shareholders – national or foreign – must present information about their final beneficiaries by the deadline of 12/31/2018 and the presentation of the supporting documentation.
It is worth clarifying that a company that does not meet this new requirement within the legal term will have its registration suspended on January 1, 2019 and will be barred from transacting by banking establishments, according to Normative Instruction of the Federal Revenue of Brazil nº. 1634 (“IN 1634/2016”).
We would like to inform you that the Rödl & Partner Paralegal Department makes available to all clients the information updating services at the Federal Revenue Service CNPJ in order to comply with the IN 1634/2016 requirement).
Michael Löb
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