Income Tax on Foreign Exchange Variation of Repatriated Assets under the RERCT

Abstract

The present study aims to investigate the possibility, in case of repatriation of assets regularized under the terms of Law 13,254/2016 which established the RERCT, the imposition of tax on income of an allegedly foreign exchange variation of such assets. In order to answer this question, it will be necessary to comprehend the incidence of tax on income on foreign exchange variation as well as to, afterwards, verify the material aspect of the tax on income described on the RERCT. After, it will be possible to treat the (non) incidence of tax on income on foreign exchange variation in case of repatriation of assets regularized under the Law 13,254/2016.