The Internal Revenue Service published today (12/28/2018) the Normative Instruction No. 1,863 / 2018, which, among other provisions, extended the deadline for 180 days for national or foreign entities registered before the CNPJ (National Registry of Legal Entities) to update its structure until the identification of the existence or non-existence of the individual, considered/classified as the final beneficiary, regardless of the structure and origin of the Brazilian or foreign capital stock.
The updating of this information is still mandatory and, depending on the situation, in the absence of such update, companies may have the registry suspended and will be impeded of transacting with banking establishments, including the movement of current accounts, to implement financial investments and obtaining loans. In the case of companies domiciled abroad that are holders of rights on investments in the financial or capital market, the suspension of the CNPJ will even be reported to the Brazilian Securities and Exchange Commission (CVM).
Our Public and Regulatory and Banking sectors continue to monitor this rule and are available to provide any assistance related to the subject.