BRP Country Manual Trustee
Brazil
| SOURCE OF CHANGES | ANSWERS |
|---|---|
| Law/Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s interpretation | No |
BRP has published its latest Country Manual Trustee for
Brazil
Regulatory Summary
Material changes
The content has been reviewed to ensure that all documents remain accurate and in line with the interpretation of the current legal framework.
With regard to Trustee activities, we can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual.
Otherwise, tax rules have been introduced in 2024 (in relation to CFC rules), which has led to changes only in the dedicated section (Chapter F).
Non-material changes
Some comments and content have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.
Behaviour Template
For the sake of consistency, all the answers relating to Trustee activities (which are not regulated per se) have been harmonised, e.g. activities related to the collection of supporting information.
Regarding regulated activities, we have aligned the first two answers of each section in accordance with the CM PB. Therefore, answers concerning the presentation and the provision of marketing documentation of a custodian bank, asset manager or investment advisor are now a ‘Grey zone’ onsite (instead of ‘Grey zone/YES’). In fact, these activities are based on an unofficial tolerated practice that could become stricter depending on the regulator’s approach.
For more information, please contact us: info@brpsa.com
Geneva, March 25th, 2025