Dutch Holding Companies Included in Brazilian Grey List: Controlled Foreign Company, Thin Capitalization and Consolidation Rules Not Applicable for 2015

This article considers the material and temporal extent and effect of the changes to the Brazilian list of privileged tax regimes in relation to Dutch holding companies and, specifically, if these changes have implications for 2015 that affect filing in respect of the Escrituração Contábil Fiscal (Digital Accounting Register, ECF) in 2016.