Response to Inquiry no. 53/14, issued by the General Coordination of the Tax System (“COSIT”), was published on Mar. 10, 2014, establishing the position on the mandatory requirement to provide information through the Foreign Trade Integrated System of Services, Intangibles, and Other Transactions Producing Equity Variation (“SISCOSERV”), related to transactions between those resident or domiciled abroad, including by branches, offices, or agencies located in Brazil of legal entities domiciled abroad.
The reason is that, according to COSIT, the terms “renderer” and “acquirer” of services resident or domiciled in Brazil dealt with in article 1, paragraph 4 of RFB Normative Rule no. 1,277/12, comprise any person having tax liability capacity, therefore including the establishment located in the Country of a legal entity domiciled abroad.