[Free translation]
As already reported in our Information 29-16, through IN RFB nº 1.634 / 16, some important issues regarding the CNPJ were changed, and its main novelty is the insertion of rules regarding the figure of the "Final Beneficiary", in order to to combat corruption and money laundering. The IN defines the final beneficiary as the natural person who ultimately, directly or indirectly, possesses, controls or influences a particular entity.
Based on this, the Federal Revenue Service of Brazil informs that new qualifications were created, among them the "69 - Final Beneficiary", for the inclusion / alteration events of Members and Managers (QSA) of entities domiciled abroad - EDEX. The QSA will be completed in accordance with the constituent act or certificate of full content.
The deadlines for the adequacy of the registrations in order to inform the final beneficiaries are as follows:
a) The foreseen obligation in relation to the need of information of the final beneficiary and the delivery of documents of foreign investors begins on January 1, 2017, for the entities that register as of that date; and,
b) entities already registered with the CNPJ before January 1, 2017 must inform the final beneficiaries when they make any registration changes as of that date, or until the deadline of December 31, 2018.
