On 4 October 2012, the National Treasury Council of Brazil (CONFAZ) published several Agreements to authorise the States of Rio Grande do Sul, São Paulo, Goiás, Sergipe, Alagoas, Rio Grande do Norte, Maranhão, Piauí, Tocantins, Amazonas and Roraima to implement tax amnesty programmes in relation to debts of Interestadual e Intermunicipal e de Comunicação (State VAT or "ICMS") and Imposto sobre Transmissão Causa Mortis e Doação (Tax on Transmission of Assets by Donation or Mortis Causa or "ITCMD"), whose tax triggering events have occurred in 2012.

Currently, out of the 11 States authorised to execute amnesty programmes, the States of Rio Grande do Sul, Amazonas and Maranhão had already issued State regulations to discipline the tax amnesty programmes.

In the State of Rio Grande do Sul, Decree n. 49,714/12 was issued to regulate the amnesty programme "Em dia 2012." The Decree provides that taxpayers interested shall apply to the programme until 30 November 2012. The programme includes debts of ICMS whose tax triggering events occurred until 31 August 2012. The table below presents the payment conditions under the referred amnesty programme.

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In the State of Amazonas, State Law n. 3,823/12 provides for a tax amnesty programme for both ICMS and ITCMD (State tax on donations and inheritance). With regard to the ICMS, Law n. 3,823/12 establishes that ICMS related to tax triggering events that occurred until 30 June 2012 can be paid under the amnesty programme, as long as the deadline application of 30 November 2012 was respected.

Also, the amnesty programme created by the State of Amazonas provides special payment conditions for debts arising from penalties arising from violations to ancillary tax obligations. In this case, the debt can be paid with a 50 percent discount if the payment is made until 31 October 2012.

The table below provides a summary of the conditions for the payment of ICMS debts under the amnesty programme of the State of Amazonas:

ICMS

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With regard to the conditions of the amnesty programme applicable to the payment of ITCMD debts in the State of Amazonas, please see the table below.

ITCMD

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Finally, the State of Maranhão issued the Administrative Resolution n. 33. This Resolution created in Maranhão the amnesty programme for the payment of ICMS debts arising from tax triggering events which occurred until 31 December 2011. The debt can be paid with 100 percent penalties' and interests' discount if a lump sum payment is made until 31 October 2012.

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With regard to the other member states that were authorised to execute ICMS Tax Amnesty Programs, the issuance of the respective state regulation is still pending to date.