Brazil is a continental country organized in the form a Federation where the Union, the States and Cities have the constitutional power to tax. In federations subject to non-centralized structures, as it is the case of Brazil, tax collection is specially associated with political leverage. The complexity derives from the various key actors (federal, state and city lawmakers, governors, mayors) with specific agendas backed by the apportionment of tax revenues.
On 12/28/2016, the Brazilian Federal Revenue enacted Regulation #1.681 introducing the rules on the Country-by-Country (CbC) Reporting standard under the Base Erosion and Profit Shifting (BEPS) Action 13. Brazil was one of the first G-20 to enact rules applicable to FY2016. Information was required to be reported in the (ECF) electronic tax returns transmitted until 7/31/2017.
With the benefit of hindsight in a post-financial crisis world, the G-20 group concluded that enhancing transparency for tax administrations was key for tackling base erosion and profit shifting (BEPS). G-20 commissioned the OECD to analyze the problem in 2009. In 2013, the OECD announced the action plans on BEPS intended to modernize the global tax system at a moment of transition between industrial and digital economies and counterpoint tax avoidance strategies that take advantage of gaps of the legislation.