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Percentage of the tax rate applicable upon non-resident investors' operations carried out based on CMN Resolution 2689/2000

Below we present two tables and each one of them contain the percentage tax rates that are applicable upon non-resident investors' operations.

It is worth highlighting that the applicability or non-applicability of the taxation, as well as its percentage tax rate depends upon the origin of the investment, being different for those arising from countries or dependencies that do not tax income or that do tax income at a percentage below 20%. Greater details as to this subject may be obtained through the Normative Ruling of the Internal Revenue Service (SRF) 188/2002, which presents the list of countries that are framed in such distinct taxation situation. (This Ruling is available in the website http://www.receita.fazenda.gov.br/Legislacao/ins/2002/in1882002.htm.) Such countries are labeled as "favored taxation" by the Brazilian legislation and the remaining countries as "non-favored taxation".

Percentage of tax rate applicable upon non-resident investors originated from “non-favored taxation” localities.
Tax Stocks or Stock Index Other Derivatives Fixed Income
In the Stock Market Outside the Stock Market In the Stock Market Outside the Stock Market
Capital Gains Exempt 15% Exempt 10% 0% or 15% **
Currency Exchange Flow* Exempt 0.38% 0.38% 0.38% 0.38%
* Entry in Brazil or remittance to a foreign country of financial resources. (The taxation occurs according to the destination of the resources.)
** The fixed income capital gains (named "rendimentos" [earnings] in Brazil) referent to Federal public stock possess zero tax rate percentage and the remaining cases, 15% percentage of tax rate.

Percentage of tax rate applicable upon non-resident investors originated from “non-favored taxation” localities.
Tax Stocks or Stock Index Other Derivatives Fixed Income
In the Stock Market Outside the Stock Market In the Stock Market Outside the Stock Market
Capital Gains 15% 15% 15% 10% Depends upon due date**
Currency Exchange Flow*  Exempt 0.38% 0.38% 0.38% 0.38%
Investments Exempt 0.38% 0.38% 0.38% 0.38%
Day Trades 20% 20% 20% 20% n.a.
* Entry in Brazil or remittance to a foreign country of financial resources. (The taxation occurs according to the destination of the resources.)
** The percentage of tax rate referent to fixed income capital gains (named "rendimentos" [earnings] in Brazil) are:
  • 22.5% for operations up to 180 days;
  • 20% for operations from 181 days to 360 days;
  • 17.5% for operations from 361 days to 720 days;
  • and 15% for operations above 720 days.

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