Pursuant to Normative Instruction RFB no. 1634/16, legal entities enrolled with the CNPJ must inform to the Federal Revenue the chain of ownership interest, until reaching the natural persons characterized as final beneficiaries. The obligation applies, including, abroad, to Silent Partnerships (SCPs), whose ostensive partners must inform the ultimate beneficiary(ies).
The inexistence of a final beneficiary must also be informed. Failure to disclose the beneficiary or to complete the documentation required by the Federal Revenue may result in the following sanctions: (i) suspension of enrollment in the CNPJ; and (ii) impediment to transactions with Brazilian banking institutions, including with respect to the movement of current accounts, making financial investments and obtaining loans.
08The team at Barcellos Tucunduva Advogados is prepared to assist you in complying with this obligation.
