The Brazilian perspective Brazilian companies have two main instruments for remunerating shareholders for the capital invested in companies: dividends and interest on net equity (“Juros sobre o capital própio”, referred to as “IoNE” in this article). Both instruments can be used at the same time, but their tax treatment will depend on the particular characteristics of each case. While dividends feature in most jurisdictions, IoNE is unique to the Brazilian system. The following paragraphs focus on describing -and characterizing IoNE- under Brazilian domestic legislation from the perspective of tax and corporate law.
Journal of International Taxation, Nº 2
Pedro Saavedra y Antonio Pereira, Garrigues. Henrique Erbolato y Daniel Marcondes, CFA Advogados, Sao Paulo, Brasil