Normative Instruction No. 1,634/2016 of the Federal Revenue Service of Brazil requires that national or foreign entities registered with the National Registry of Legal Entities (CNPJ) must, by the deadline of December 31, 2018, update their corporate structure until identifying the existence or non-existence of an individual who is the ultimate beneficiary. This applies regardless of the levels of the structure and the origin of the share capital, whether Brazilian or foreign.
Updating the registration information is mandatory. If it is not submitted, companies may have their registration suspended and will be prevented from transacting with banking establishments. This includes the movement of current accounts, the making of financial investments, and the obtaining of loans.
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Federal Revenue Service updates CNPJ rules relating to the concept of ultimate beneficiary
More information can be obtained on the Federal Revenue Service website.
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