Export Prepayment Agreements

Abstract

The article seeks to demonstrate that the correct interpretation of art. 1, item XI, of Law 9481/1997, is that the zero rate of withholding income tax on interest and commissions related to credits received abroad and destined for export financing must be recognized (i) when the taxpayer performs exports; and (ii) when the banks certify proof of tax compliance and the legality and economic basis of the operation, it being inappropriate to demand other requirements for the application of the tax incentive.