Thin Capitalization Rules Introduced, Yet Some Uncertainties Remain

Provisional Measure 472 of 2009, which introduced thin capitalization rules in the Brazilian tax system, gave rise to much controversy among tax practitioners, particularly as regards the application of some of its provisions. These were substantially resolved with the introduction of new provisions on the same subject by the time Provisional Measure 472 was converted into Law 12,249/2010. Nevertheless, there remain some unresolved issues.